On February 2, 2015 the Obama Administration acknowledged the
plight of certain US citizens residing abroad and proposed limited
relief. In the "General Explanations of the
Administration's Fiscal Year 2016 Revenue
Proposals"1, known as the "Green
Book," the Administration proposed a change to US law (the
"Proposal") that would allow certain dual citizens to
renounce their US citizenship without the fear of delinquent tax
filings, penalties, the US exit tax, and the other consequences to
being a covered expatriate.
The details of the Proposal, and the chances of being given the
effect of law, while interesting, are less so than the
Administration's motive for advancing it. Politicians don't
get re-elected by winnowing away their constituency base or
enacting legislation that has the effect of raising tax (even in
small measures). Normal people, even politicians, behave rationally
so there must be a reason for the Proposal. Could the Proposal play
a small part in a
