[philiphodgen]

At the moment the U.S. government is remarkably sane about this. People who renounce citizenship can re-enter the USA on tourist visas, get work visas (like an L-1), etc. They can even get green cards and re-acquire citizenship.

"Sane" will continue until we have a critical mass of people like Senator Schumer in the Senate.

Disclaimer: I am a lawyer. And I do lots and lots of expatriation cases.

[victorf]

But not if you explicitly renounce to avoid taxes, there's a checkbox for that in amongst the "have you ever committed acts of terror?" questions.

[philiphodgen]

That checkbox is a legacy of the pre-2008 laws, which had different tax treatments depending on your motivation for renouncing citizenship.

Under the current laws, intent is irrelevant. If you meet certain criteria (net worth above $2 million, for most people) you pay tax. Our friends in Congress want to define people as meeting these criteria as having evil tax-avoidance motives. It ain't so, at the moment.

And of course NO ONE ever tells the Embassy official that the primary motive for renouncing citizenship is tax-driven. :-)

Seriously, though. I would say that at least half of the people I work with end up living in high income tax countries (Canada, various countries in Europe, Australia, New Zealand). They aren't leaving to cut their income tax bills. The tax-drive motivations are primarily (1) the craptastic paperwork and horrific penalties that Americans abroad face, and (2) the estate tax.