The Case Against Taxing Citizens

12 Pages Posted: 31 Mar 2010 Last revised: 13 Apr 2010

Date Written: March 25, 2010


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.

Keywords: citizenship, international taxation

JEL Classification: H24

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: or

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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