Cook-v-Tait

Formal renunciation of U.S. citizenship under 8 U.S.C. § 1481 severs the citizenship-based federal jurisdiction that follows U.S. citizens worldwide, subject to the Reed Amendment, the exit tax under § 877A, and FATCA reporting on pre-renunciation accounts

Formal expatriation under 8 U.S.C. § 1481 works. The § 877A exit tax applies on the way out. Past obligations don't retroactively disappear, but going-forward U.S. citizenship-based taxation does. One of the six real exits identified in the capstone analysis, operative as designed — though structurally available only to the wealthy.