I don't think that's what he's saying. I think we are talking past each other, myself included. a) cole seems to specifically be talking about very wealthy peo

I don't think that's what he's saying. I think we are talking past each other, myself included. a) cole seems to specifically be talking about very wealthy people who did work and earn money in the US but who renounced citizenship largely for tax purposes (e.g. Eduardo Saverin) b) cole talks about the foreign-earned income exclusion, which is misplaced (for people like (a) this is very different from income earned on investments and for wealth which is subject to the exit tax) There's a smattering of outright incorrect things too like having to pay taxes for 10 years after renouncing.