One of the most controversial policy issues in the U.S. international tax law is the application of U.S. taxes to “accidental Americans.” The term is often used to describe individuals who were born in the U.S. and who therefore became U.S. citizens at birth, moved abroad at an early age and maintained little contact with the U.S. thereafter, but who never formally renounced their U.S. citizenship or otherwise expatriated.
Suppose that a whistleblower learns that a wealthy foreign citizen residing abroad may well be such a U.S.-born accidental American. If the whistleblower provides this information to the IRS Whistleblower Office in an Application for Award claim form—Form 211—may the IRS Whistleblower Office reject that claim?
This was the issue in Whistleblower 15977-18W v. Commissioner, decided by the U.S. Tax Court in December 2021. In sustaining the IRS rejection of the claim, the opinion seemed to conclude that the target’s U.S. birth certificate was not “specific and credible information” that the target acquired U.S. citizenship at birth. The Tax Court later noted that even assuming that the target acquired U.S. citizenship at birth,...
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