This tax provision is not designed to be friendly. It's designed to deter what the US considers bad behavior. You can disagree that it's bad behavior, you can c

This tax provision is not designed to be friendly. It's designed to deter what the US considers bad behavior. You can disagree that it's bad behavior, you can call the law is unfair, immoral, unreasonable, illogical -- whatever. Arguing against those positions is not the point of the post I made. My point was to point out that there isn't any loophole in U.S. that would allow a cryto billionaire to avoid capital gains taxes via the expedient of renouncing citizenship. People can try anyway and see what happens, but there's a non-zero risk that they'll be chased to the ends of the earth by the IRS and DOJ.