On February 2, 2015 the Obama Administration acknowledged the plight of certain US citizens residing abroad and proposed limited relief.

In the “General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals”¹, known as the “Green Book,” the Administration proposed a change to US law (the “Proposal”) that would allow certain dual citizens to renounce their US citizenship without the fear of delinquent tax filings, penalties, the US exit tax, and the other consequences to being a covered expatriate.

The details of the Proposal, and the chances of being given the effect of law, while interesting, are less so than the Administration’s motive for advancing it.

Could the Proposal play a small part in a more subtle strategy that might involve foreign opposition to FATCA and IGA-partner domestic legislation?

Regardless of the Proposal’s chance of being given the effect of law, the Administration’s motivation for bringing it forward, or the narrow class of individuals to whom it would apply, the Proposal is positive step.

It is evidence that the unenviable predicament faced by dual citizens living abroad has been heard in Washington, DC and there may be the political will to affect change. Change may come quickly or not at all, but it will never come until there is understanding of the issue. The Proposal is an indication that understanding may be taking hold.