Married couple, US Citizens, have lived in England since 1992. Only twice in that time has earned income exceeded Foreign Income Exclusion. They are in their mid-fifties. Husband only has 35 quarters of Social Security coverage and will not qualify for a benefit. Wife's benefit is projected to be $350 a month at FRA; this information came from Social Security.
Reason for question is their personal residence, which if sold today, would produce a 1.9M gain. They believe there is no UK tax on the sale of residence (they sold a second residence this past year and while some tax was paid to the UK, it was far less than the US tax on gain of about 85K). So they ask about becoming ex-pats or possibly having husband renounce citizenship and transferring house to his name.
Aside from a bank account, they have no assets in the States.
What say you?