is only required to contain covered expatriates. Additionally, the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 included a provision, the Reed Amendment (), to bar entry to any individual "who officially renounces United States citizenship and who is determined by the Attorney General to have renounced United States citizenship for the purpose of avoiding taxation by the United States". However, former IRS lawyers, as well as the Department of Homeland Security, have indicated that the provision is unenforceable because there is no authority for the IRS to share tax return information to enforce it. DHS stated that they can only enforce the Reed Amendment when former US citizens "affirmatively admit to renouncing their U.S. citizenship for the purpose of avoiding U.S. taxation", and between 2002 and 2015 they denied entry to only two former US citizens on the basis of the amendment. In 2008, Congress enacted the Heroes Earnings Assistance and Relief Act, which changed the expatriation tax to a one-time mark-to-market worldwide capital gains tax rather than ten years of taxation on US-source income. Effective June 2008, US citizens who renounce their citizenship are subject under certain circumstances to an expatriation tax, which is meant to extract, from the expatriate, taxes that would have been paid had he or she remained a citizen. All property of a covered expatriate is deemed sold for its fair market value on the day before the expatriation date, which usually results in a capital gain, which is taxable income. Eduardo Saverin, a Brazilian-born co-founder of Facebook, renounced his US citizenship just before the company's expected initial public offering. The timing prompted media speculation that the act was motivated by potential US tax obligations. Since the enactment of FATCA in 2010, the numbers of people renouncing US citizenship have broken new records each year, increasing from a few hundred per year before FATCA to 5,411 in 2016. In the first two quarters of 2017 alone, 3,072 people renounced, which exceeds the full year total for 2013. In 2016, there were about 18 times more renunciations than in 2008, and the 2017 quarter 2 total (1,759) is more than 76 times that of quarter 2 in 2008 (23). Renunciants have reported that they feel forced to renounce under duress caused by FATCA but are prevented from saying this when renouncing. References Citizenship Acquired citizenship International taxation Tax avoidance