http://blogs.reuters.com/felix-salmon/2012/05/17/eduardo-saverin-joins-the-stateless-billionaires/
---------------------------snip
In January 2011, after moving to Singapore, Saverin decided that he
wanted to give up his US citizenship. He didn’t live in the US, he was
going to have lots of income going forwards, and he felt that there
was no good reason for him — a citoyen du monde — to pay 35% of that
income to the USA in particular. Not to mention estate and gift taxes
for when he finally passes on his wealth to someone else.

If Saverin hadn’t been a US citizen, all of this would have been a
non-issue: simply moving to another country suffices to relieve you of
most of your tax burden in your country of nationality. But because he
was a US citizen, he took the drastic step of renouncing that
citizenship; the move became official in September. And then, in a fit
of extraordinarily bad timing, from a PR perspective, the news came
out just as Facebook was about to go public, and, faster than you can
say “press conference”, Chuck Schumer decided that he was going to
introduce something called the Ex-PATRIOT Act. (Geddit?) Under the
act, people like Saverin renouncing their US citizenship for tax
purposes would face fines so huge that they’d be better off not doing
so at all.

The rhetoric, here, is that Saverin’s success is attributable to his
American citizenship, and that therefore America deserves to be able
to receive its condign tax revenues. And I half buy it, although
frankly there’s nothing stopping any rich Brazilian kid from going to
Harvard and funding a startup. Saverin didn’t need US citizenship to
do what he did.

This is an issue which pops up occasionally: it’s already very onerous
to give up US citizenship. Kathy Kristof had a good overview of the
history of such laws in 2008: a 1996 law, for instance, forced former
US citizens to continue paying taxes on their worldwide income for at
least five years, and in 2004 that was extended to 10 years. In 2008,
a new law forced people like Saverin to pay capital gains taxes on the
assumption that they liquidated all their property the day before they
renounced their citizenship. And indeed, that’s what he did.

Still, Saverin can still be considered to be saving taxes here, since
Facebook now is worth substantially more than it was worth in
September. At the same time, he’s facing a nightmare at US immigration
— entering the country might well be impossible, and it could be
extremely difficult just to change planes here. He’s not just another
Brazilian any more: he’s the lowest of the low as far as US
immigration is concerned, and they will never treat him with any
respect at all. Since he doesn’t have much in the way of rights any
more — he gave most of those up with his citizenship — he’d be well
advised to avoid the USA pretty much for the rest of his life.

>From a public-policy perspective, this is the kind of US
exceptionalism I can get behind. There’s a corrosive class of global
plutocrats, living by choice in tax havens like Singapore or
Switzerland, and paying vastly less in taxes than Mitt Romney or any
US billionaire. If you’re not an American citizen, and you become
incredibly wealthy, there’s a good chance that you will choose to
become a tax exile — thereby depriving your home country of the income
taxes it should expect to be able to raise from its richest citizens.
It’s a country-of-residence tax arbitrage which makes the ultra-rich
feel no civic duty at all to their countries. And somehow the US has
managed to avoid that problem: American billionaires, as a rule,
remain American billionaires, as do their children and their
children’s children. They — along with the Chinese — are pretty much
the only billionaires in the world who don’t live a stateless
existence. And even the Chinese ultra-rich are rapidly breaking free
of their home country.

So yes, it’s a little bit unfair to Saverin that he’s suffering so
much opprobrium right now when he would be getting none of this were
it not for the accident of his US citizenship. But I can’t really feel
sorry for him. And if the US succeeds in making an example of him, it
will have managed to pull off something very important — which is to
keep its billionaires part of the tax base. Very few other countries
can say that.
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