Essentially, yes. A person who renounces U.S. citizenship is generally not able to take advantage of the special visa programs (like the EB5 investor program) to regain residency. Furthermore, their applications for visas, etc., are also (informally) put in the lowest-priority bracket unless they pony up to be placed in the priority queue.
Moreover, any attempt to renounce their renunciation of citizenship results in a hefty tax bill for the period they were not a citizen, as the initial renunciation will be treated (by the IRS) as an attempt to evade taxation.
Indeed, merely returning to the U.S. for a period of more than 183 days (one of the tests for residence for taxation purposes) could trigger this result.
EDIT: Also note, as discussed below, he would be deemed "inadmissible" for re-entry if he was deemed to have a tax avoidance motive for renouncing his citizenship. The consequence would be a permanent ban from the U.S. (and the hefty tax bill would remain intact).
I think you greatly overestimate how much power a billion dollars provides...especially since the IRS would lay claim to that billion if he ever tried to return to the U.S. Why would they work out a deal when they could get their hands on the billion and have an example for future tax evaders?
Note: I use the term tax evader in this context because if Saverin attempts to return to the U.S. in the future (as a resident or citizen), it will be clear that his renunciation of citizenship was primarily for the purpose of evading taxes.
Comments
Essentially, yes. A person who renounces U.S. citizenship is generally not able to take advantage of the special visa programs (like the EB5 investor program) to regain residency. Furthermore, their applications for visas, etc., are also (informally) put in the lowest-priority bracket unless they pony up to be placed in the priority queue.
Moreover, any attempt to renounce their renunciation of citizenship results in a hefty tax bill for the period they were not a citizen, as the initial renunciation will be treated (by the IRS) as an attempt to evade taxation. Indeed, merely returning to the U.S. for a period of more than 183 days (one of the tests for residence for taxation purposes) could trigger this result. EDIT: Also note, as discussed below, he would be deemed "inadmissible" for re-entry if he was deemed to have a tax avoidance motive for renouncing his citizenship. The consequence would be a permanent ban from the U.S. (and the hefty tax bill would remain intact).
A billion dollars is powerful. If he wants to; I'll bet that Saverin will find a way to live in the U.S. again.
I think you greatly overestimate how much power a billion dollars provides...especially since the IRS would lay claim to that billion if he ever tried to return to the U.S. Why would they work out a deal when they could get their hands on the billion and have an example for future tax evaders?
Note: I use the term tax evader in this context because if Saverin attempts to return to the U.S. in the future (as a resident or citizen), it will be clear that his renunciation of citizenship was primarily for the purpose of evading taxes.