of any government. In one case, Vincent Cate, an encryption expert living in Anguilla, chose to renounce his US citizenship to avoid the possibility of violating US laws that may have prohibited US citizens from "exporting" encryption software. Renunciation fee Renunciation of US citizenship was free until July 2010, at which time a fee of $450 was established. An increase of 422 per cent, to $2,350, effective September 6, 2014, was justified as "reflective of the true cost" of processing. Documentation of a prior relinquishment of US citizenship was free until November 9, 2015 when the renunciation fee of $2,350 was extended to cover all documentation of loss of citizenship. On October 26, 2015, Forbes reported that during 2014, American dual citizens in Canada who were trying to renounce their U.S. citizenship created a backlog at the US Consulate in Toronto. Taxation People giving up US citizenship may be subject to an expatriation tax. Originally, under the Foreign Investors Tax Act of 1966, people determined to be giving up citizenship for the purpose of avoiding US taxation were subject to 10 years of continued taxation on their US-source income, to prevent ex-citizens from taking advantage of special tax incentives offered to foreigners investing in the United States. In 1996, the Health Insurance Portability and Accountability Act included various changes to the tax treatment of people who give up US citizenship. First, it defined concrete criteria to determine whether an ex-citizen or ex-permanent resident was a "covered expatriate" presumed to have given up US status for tax reasons, based on the person's income and assets, or inability to certify compliance with their tax filing and payment obligations for the past five years (). Second, it required the Department of the Treasury to "name and shame" people who give up US citizenship by listing their names in the Quarterly Publication of Individuals Who Have Chosen to Expatriate in the Federal Register (. The list does not appear to contain the names of all people who give up US citizenship, though tax lawyers disagree whether that is because the list is only required to contain "covered expatriates", or due to bureaucratic errors or other reasons. Names of those renouncing in the last months of the year will mostly appear on the list before they have filed IRS form 8854 establishing covered or non-covered status, so it does not seem possible that the list