 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 is only required to contain covered expatriates.Additionally, the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 included a provision, the Reed Amendment (), to bar entry to any individual "who officially renounces United States citizenship and who is determined by the Attorney General to have renounced United States citizenship for the purpose of avoiding taxation by the United States".