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).