The Case Against Taxing Citizens
Reuven S. Avi-Yonah
University of Michigan Law School
March 25, 2010
U of Michigan Law & Econ, Empirical Legal Studies Center Paper No. 10-009
U of Michigan Public Law Working Paper No. 190
The US is the only developed country to tax citizens living permanently overseas on their worldwide income. This rule was created at a time when the income tax applied only to the rich and when some of the rich moved overseas to avoid the draft. We do not have a draft any more, the income tax applies to the middle class, and many more US citizens live permanently overseas for non‐tax reasons. In a globalized world, citizenship‐based taxation is an anachronism which should be abandoned.
Number of Pages in PDF File: 12
Keywords: citizenship, international taxation
JEL Classification: H24
Date posted: March 31, 2010 ; Last revised: April 13, 2010
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