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It doesn't but all that means is the form for renouncing has a checkbox asking "are you doing this for tax reasons"? And you check "no". Then during the consular interview you spew some line about how you no longer have attachments to the US -- "I haven't been back in over 3 years, own no property, let my driver's license expire" and you do have attachments in your new country "All my friends are here and I even spend Christmas here!"

It is more of a retroactive "if we find out later you lied we now have a legal basis to add extra penalties" but in practice nobody is really checking or cares. The underfunded IRS doesn't care about the tiny number renouncing and the consular officials doing the interview certainly don't care.




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