This Is Permanent — Consider All Alternatives First
Renouncing US citizenship is irreversible. You lose the right to live and work in the US without a visa, US passport, access to US Social Security (in some cases), and the ability to pass US citizenship to future children. Most tax advisors recommend exhausting all compliance optimization strategies before considering renunciation. Consult multiple specialists before proceeding.
The US Exit Tax — Who Pays and How Much?
The US imposes a "mark-to-market" exit tax on covered expatriates who renounce citizenship:
- You are a covered expatriate if ANY of these apply: (1) Your average annual net income tax for the 5 years before renunciation exceeds a threshold ($190,000 in 2024); OR (2) Your net worth on the date of renunciation is $2M or more; OR (3) You failed to certify 5 years of US tax compliance (Form 8854)
- If you ARE a covered expatriate: The IRS treats ALL your worldwide assets as if sold on the day before renunciation. Capital gains above a $866,000 exemption (2024) are taxable at the applicable US capital gains rate.
- If you are NOT a covered expatriate: No exit tax owed, but you still must file a final US return and Form 8854
- Certain assets have special rules: IRAs/401(k)s are taxed as ordinary income. Foreign pensions are also marked to market.
The Renunciation Process at US Embassy Paris
- Request an appointment at the US Embassy Paris — wait times can be 6–18 months due to high demand
- Bring: US passport, French residency documents, completed Form DS-4079 (request to renounce)
- You will take an oath of renunciation before a consular officer — this is the formal act of renunciation
- Pay the $2,350 fee (highest renunciation fee of any country in the world)
- Receive a Certificate of Loss of Nationality (CLN) — this is your proof of renunciation
- After renunciation: file final US tax return, Form 8854 (expatriation statement), and any exit tax owed
- You will continue to receive a US Social Security statement after renunciation if you qualify, but benefits may be affected
FATCA Compliance
The trigger for many renunciation decisions