A colleague recently fielded a call from an American living in Europe who is considering renouncing U.S. citizenship - not for tax reasons, as the caller does not have the income or wealth to make that a consideration, but because of the obligations we impose on expatriates.
Unlike most countries, which tax only residents, we expect our citizens to pay taxes on their worldwide income no matter where they live. We require them to file separate annual reports on their foreign bank accounts (along with new disclosures demanded on many tax returns) under threat of draconian penalties, even when there is no tax avoidance. And we demand that foreign banks report Americans’ holdings to our government, a burden that has led many institutions to limit their business relationships with our expatriates.
These burdens might be excessive, but we can at least view them as a price to pay for the privileges that accompany our citizenship. If you are an American, you can walk up to any U.S. Customs counter, present your passport and know that you are legally entitled to dwell and work in this country, no matter what the person sitting in that booth may think of you. You also live under the protection of a government that operates around the globe, backed when necessary by the most powerful armed forces the world has ever seen.
So my colleague, Paul Jacobs of our Atlanta office, advised his caller to consider very carefully the ramifications of renouncing his American birthright. If he still wishes to proceed, we will be glad to help with the financial aspects of the process.
I agree with everything Paul told his caller, but late last week I had to wonder whether I could deliver the same patriotic speech, in good conscience, in the wake of President Obama’s widely reported recalibration of the war on terror.
Though murky about many details, Obama made clear that he has grown tired of this struggle, and he presumes that most Americans have grown tired of it, too. He sought to redefine U.S. objectives “not as a boundless ‘global war on terror’ but rather as a series of persistent, targeted efforts to dismantle specific networks of violent extremists that threaten America.”
If our government chooses to fight only “specific networks” that “threaten America,” what should I say to a U.S. citizen in a European capital, who is just as much a target as anyone in New York City, and probably much more accessible to attackers? Do I just tell him to come home if he wants his government to protect him?
America is fighting a global battle against terror because terror targets Americans globally. Obama is not the first president to bear this burden. He is simply the first president to reject it.
Our citizens have been targets around the world for decades. Leon Klinghoffer, a wheelchair-bound retiree from New Jersey, was shot in the forehead by the Palestinian hijackers of the Achille Lauro cruise ship in the Mediterranean in 1985. The murderers then forced two crew members to throw Klinghoffer’s body and his wheelchair overboard. (Klinghoffer’s body, recovered by Syria, was returned to the U.S. He and his wife are buried in New Jersey.)
The 1986 bombing of a West Berlin disco killed two people, including a U.S. soldier, and wounded 120, around 40 of whom were Americans. Two years later, Pan Am Flight 103 was blown out of the sky over Lockerbie, Scotland, killing 259 aboard the aircraft (including 179 Americans) and 11 people on the ground. Both attacks were blamed on the Libyan government of Col. Moammar Gadhafi; U.S. forces bombed his personal compound in 1986 in reprisal for the Berlin incident.
The 1990s brought a litany of outrages, including the first attack on the World Trade Center (1993), the bombing of two U.S. embassies in Africa (1998), the attempted millennium bombing of Los Angeles International Airport (thwarted in the last days of 1999), the attack on the U.S.S. Cole while it was docked in Yemen (2000) and, finally, the events of Sept. 11, 2001. Some of these attacks took place on our shores, some thousands of miles away, but all were coordinated or assisted by people abroad whose sole objective was to kill, maim and terrorize as many Americans as possible. Though al-Qaida was a player in all these incidents to varying degrees, terrorists don’t incorporate their organizations, nor do they always follow hierarchical chains of command. To target only “specific networks” of terrorists is to presume, with no factual basis, that we know exactly which terrorists are in which networks at any point in time, and which of those networks are targeting us.
Through a combination of extremely hard work, close cooperation with other nations and sheer luck, we have avoided any incidents of mass carnage inside the United States since 9/11. (This is not the case elsewhere, as the mass-transit attacks on Madrid in 2004 and London in 2005 attest.) There have, however, been many smaller incidents and close calls, including the Fort Hood shootings and underwear-bomb attempts of 2009, the printer-cartridge bomb that was intended for a cargo plane in 2010, the Times Square attack the same year, and of course the Boston Marathon bombing this year. Abroad, the killing of an ambassador and three other Americans in Benghazi last year was the worst incident, but not the only one. All of these recent events have happened on Obama’s watch.
This may be why the president did not declare the war on terror to be over, exactly. He simply made the self-evident observation that “this war, like all wars, must end.” While meaningless to Americans, it was probably an encouraging signal to all the would-be killers whose greatest fear is an American drone-fired missile. Obama did not promise an immediate end to the drone program, but he proposed multiple restrictions, including a new criterion for assaults: a near-zero likelihood of non-combatant casualties.
Every violent radical abroad will hear that message loud and clear. If you use your families or other nearby innocents as human shields, you are safe. To Americans abroad, as well as to our allies and part-time friends who sometimes offer critical assistance, there is another message: You are on your own.
At its heart, the president’s speech was a call for the United States to return to the posture we held in the 1990s, when we treated each incident as an isolated crime. These brought solemn vows of punishment that, ultimately, never came.
The speech will be heard, in capitals around the world as well as in terrorist hideouts, as a declaration by this president that he refuses to let global security concerns rule the rest of his term in office, no matter what the actual situation on the ground may be. Obama appears to believe that if you can’t see an end to the global terrorism fight, you should just declare it over, so that you can get on with the things you want to do before you write your memoirs.
He might call the last installment of his autobiographical trilogy Cairo On The Potomac: My Days As King Of Denial.
I don’t know what to tell the next American who calls to talk about renouncing citizenship, except this: A U.S. president’s term only lasts four years, but when you walk out on this country, you do so forever.
Posted by Larry M. Elkin, CPA, CFP®
A colleague recently fielded a call from an American living in Europe who is considering renouncing U.S. citizenship - not for tax reasons, as the caller does not have the income or wealth to make that a consideration, but because of the obligations we impose on expatriates.
Unlike most countries, which tax only residents, we expect our citizens to pay taxes on their worldwide income no matter where they live. We require them to file separate annual reports on their foreign bank accounts (along with new disclosures demanded on many tax returns) under threat of draconian penalties, even when there is no tax avoidance. And we demand that foreign banks report Americans’ holdings to our government, a burden that has led many institutions to limit their business relationships with our expatriates.
These burdens might be excessive, but we can at least view them as a price to pay for the privileges that accompany our citizenship. If you are an American, you can walk up to any U.S. Customs counter, present your passport and know that you are legally entitled to dwell and work in this country, no matter what the person sitting in that booth may think of you. You also live under the protection of a government that operates around the globe, backed when necessary by the most powerful armed forces the world has ever seen.
So my colleague, Paul Jacobs of our Atlanta office, advised his caller to consider very carefully the ramifications of renouncing his American birthright. If he still wishes to proceed, we will be glad to help with the financial aspects of the process.
I agree with everything Paul told his caller, but late last week I had to wonder whether I could deliver the same patriotic speech, in good conscience, in the wake of President Obama’s widely reported recalibration of the war on terror.
Though murky about many details, Obama made clear that he has grown tired of this struggle, and he presumes that most Americans have grown tired of it, too. He sought to redefine U.S. objectives “not as a boundless ‘global war on terror’ but rather as a series of persistent, targeted efforts to dismantle specific networks of violent extremists that threaten America.”
If our government chooses to fight only “specific networks” that “threaten America,” what should I say to a U.S. citizen in a European capital, who is just as much a target as anyone in New York City, and probably much more accessible to attackers? Do I just tell him to come home if he wants his government to protect him?
America is fighting a global battle against terror because terror targets Americans globally. Obama is not the first president to bear this burden. He is simply the first president to reject it.
Our citizens have been targets around the world for decades. Leon Klinghoffer, a wheelchair-bound retiree from New Jersey, was shot in the forehead by the Palestinian hijackers of the Achille Lauro cruise ship in the Mediterranean in 1985. The murderers then forced two crew members to throw Klinghoffer’s body and his wheelchair overboard. (Klinghoffer’s body, recovered by Syria, was returned to the U.S. He and his wife are buried in New Jersey.)
The 1986 bombing of a West Berlin disco killed two people, including a U.S. soldier, and wounded 120, around 40 of whom were Americans. Two years later, Pan Am Flight 103 was blown out of the sky over Lockerbie, Scotland, killing 259 aboard the aircraft (including 179 Americans) and 11 people on the ground. Both attacks were blamed on the Libyan government of Col. Moammar Gadhafi; U.S. forces bombed his personal compound in 1986 in reprisal for the Berlin incident.
The 1990s brought a litany of outrages, including the first attack on the World Trade Center (1993), the bombing of two U.S. embassies in Africa (1998), the attempted millennium bombing of Los Angeles International Airport (thwarted in the last days of 1999), the attack on the U.S.S. Cole while it was docked in Yemen (2000) and, finally, the events of Sept. 11, 2001. Some of these attacks took place on our shores, some thousands of miles away, but all were coordinated or assisted by people abroad whose sole objective was to kill, maim and terrorize as many Americans as possible. Though al-Qaida was a player in all these incidents to varying degrees, terrorists don’t incorporate their organizations, nor do they always follow hierarchical chains of command. To target only “specific networks” of terrorists is to presume, with no factual basis, that we know exactly which terrorists are in which networks at any point in time, and which of those networks are targeting us.
Through a combination of extremely hard work, close cooperation with other nations and sheer luck, we have avoided any incidents of mass carnage inside the United States since 9/11. (This is not the case elsewhere, as the mass-transit attacks on Madrid in 2004 and London in 2005 attest.) There have, however, been many smaller incidents and close calls, including the Fort Hood shootings and underwear-bomb attempts of 2009, the printer-cartridge bomb that was intended for a cargo plane in 2010, the Times Square attack the same year, and of course the Boston Marathon bombing this year. Abroad, the killing of an ambassador and three other Americans in Benghazi last year was the worst incident, but not the only one. All of these recent events have happened on Obama’s watch.
This may be why the president did not declare the war on terror to be over, exactly. He simply made the self-evident observation that “this war, like all wars, must end.” While meaningless to Americans, it was probably an encouraging signal to all the would-be killers whose greatest fear is an American drone-fired missile. Obama did not promise an immediate end to the drone program, but he proposed multiple restrictions, including a new criterion for assaults: a near-zero likelihood of non-combatant casualties.
Every violent radical abroad will hear that message loud and clear. If you use your families or other nearby innocents as human shields, you are safe. To Americans abroad, as well as to our allies and part-time friends who sometimes offer critical assistance, there is another message: You are on your own.
At its heart, the president’s speech was a call for the United States to return to the posture we held in the 1990s, when we treated each incident as an isolated crime. These brought solemn vows of punishment that, ultimately, never came.
The speech will be heard, in capitals around the world as well as in terrorist hideouts, as a declaration by this president that he refuses to let global security concerns rule the rest of his term in office, no matter what the actual situation on the ground may be. Obama appears to believe that if you can’t see an end to the global terrorism fight, you should just declare it over, so that you can get on with the things you want to do before you write your memoirs.
He might call the last installment of his autobiographical trilogy Cairo On The Potomac: My Days As King Of Denial.
I don’t know what to tell the next American who calls to talk about renouncing citizenship, except this: A U.S. president’s term only lasts four years, but when you walk out on this country, you do so forever.
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