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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

Abstract:     
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

working papers series


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Date posted: March 31, 2010 ; Last revised: April 13, 2010

Suggested Citation

Avi-Yonah, Reuven S., The Case Against Taxing Citizens (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. Available at SSRN: http://ssrn.com/abstract=1578272 or http://dx.doi.org/10.2139/ssrn.1578272

Contact Information

Reuven S. Avi-Yonah (Contact Author)
University of Michigan Law School ( email )
625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)
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