Many US citizens living in Australia and elsewhere around the
world have found themselves faced with the difficult decision of
whether to keep or renounce their US citizenship. A decade ago, the
idea of renouncing one's US citizenship was, for most,
unthinkable. Currently, however, record numbers of individuals
renounce every quarter and many US consulates are booking
appointments 18 months in advance.1 While people choose to renounce
their US citizenship for many reasons, a common reason Australian
residents choose to do so is because of the lack of clear guidance
on the US tax consequences of Australian Superannuation funds
(Super).
For those who are unfamiliar, a Super fund is a financial
vehicle in Australia that is set up to provide an individual with
income upon retirement. Like most governments that sponsor
retirement programs, Australia encourages its citizens to
contribute to the funds by providing advantageous tax treatment for
doing so. It is estimated
