The Escape Hatch (Expatriation): The Roots and Fruits of Section 6039G

6 Pages Posted: 25 Aug 2016

See all articles by Erin Fraser

Erin Fraser

Independent; Golden Gate University

Date Written: August 22, 2016


Two weeks ago, the IRS published the latest quarterly notice pursuant to § 6039G. In plain English, the § 6039G list is a list of individuals that expatriated during the quarter preceding publication (here, the second quarter of 2016).

For readers that are new to the world of U.S. taxation, the first shock may be that § 6039G even exists. To be clear, since late 1996 the United States has purported to publish the name of every individual losing citizenship. This paper examines why.

Keywords: 6039G, 877A, Exit Tax, expatriation, FATCA, IRS, Private Clients

Suggested Citation

Fraser, Erin, The Escape Hatch (Expatriation): The Roots and Fruits of Section 6039G (August 22, 2016). Available at SSRN: or

Golden Gate University ( email )

San Francisco, CA 94105-2968
United States

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