Citizenship Taxation
72 Pages Posted: 17 May 2015 Last revised: 16 Jun 2016
Date Written: February 10, 2016
Abstract
The United States is the only country that taxes its citizens’ worldwide income, even when those citizens live indefinitely abroad. This Article critically evaluates the traditional equity, efficiency, and administrability arguments for taxing nonresident citizens. It also raises new arguments against citizenship taxation, including that it puts the United States at a disadvantage when competing with other countries for highly skilled migrants.
Keywords: citizenship, immigration, taxation, benefits theory, ability to pay, FATCA, FBAR
JEL Classification: H24, H26, K34
Suggested Citation: Suggested Citation
Ruth Mason (Contact Author)
University of Virginia School of Law ( email )
580 Massie Road
Charlottesville, VA 22903
United States
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