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Link?

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If you renounce U.S. citizenship in order to avoid income tax (which is a rebuttable presumption), and if you have a large enough tax liability over the previous five years (averaged) that you would be avoiding a significant amount of tax ($124,000 in 2004, I believe), then you will be required to fill out forms for the next ten years, and possibly pay some tax.

Here's a link from the IRS for more info. The expatriation tax rules were modified in 2004 to make it more favorable to repatriate your income.