SEAT’s Submission to U.S. Department of State

Today SEAT made a submission to the U.S. Department of State in relation to its Notice of Proposed Rulemaking – State Department Schedule of Fees for Consular Services-Administrative Processing of Request for Certificate of Loss of Nationality (CLN) Fee / RIN (1400–AF61).

The submission can be viewed here and here.

As of Thursday Novemer 2, over 800 submissions had been made. They can be consulted here.

You (anyone) can also make a submission, but you need to act fast. The deadline to submit is Wednesday November 1, 2023 at 11:59 pm EDT. It’s quick and easy to do, so don’t hesitate to make your submission. Feel free to copy as much or as little as you like from SEAT’s submission.

The link to submit is here.

The content of SEAT’s submission is as follows:

SEAT can only applaud a reduction of the renunciation fee from $2,350 to $450. However, even this is an exorbitant amount.


Hopefully the State Department understands that the real problem is not the high renunciation fee, but the fact that so many Americans feel they have no choice but to renounce U.S. citizenship.


Americans are taught from childhood that the United States is the greatest country in the world and that they are privileged to be Americans. They grow up reciting the pledge of allegiance and singing the national anthem. By renouncing U.S. citizenship in relatively large numbers, overseas Americans are communicating by their actions that something has happened to radically change how they feel about the United States, causing them to give up on what they once thought was among the most precious things they had – their U.S. citizenship. Something has gone terribly wrong.


What is wrong is the U.S. nationality-based tax system. It singles out persons of U.S. nationality living outside the United States and targets them with far more onerous federal tax burdens as compared to those who are not U.S. nationals and compared to all persons living in the United States, regardless of nationality. Further, FATCA makes it difficult – and sometimes impossible – for them to open or maintain bank and other financial accounts. Many U.S. nationals living overseas feel that the only way they can live a normal life in the places where they live is to renounce U.S. citizenship.


This occurs in violation of both their constitutional and human rights. Citizenship is a constitutional and a human right. Leaving one’s country and returning to it are human rights. In feeling they have no choice but to renounce U.S. citizenship, all these rights are violated.


Instead of charging Americans living overseas exorbitant fees to attain the ability to live a normal life, the State Department should be advocating to Congress to end its discriminatory policies that harm Americans living overseas.





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