72 Pages Posted: 17 May 2015 Last revised: 16 Jun 2016
Date Written: February 10, 2016
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
Mason, Ruth, Citizenship Taxation (February 10, 2016). Southern California Law Review, Vol. 89, Forthcoming; Virginia Law and Economics Research Paper No. 2015-07. Available at SSRN: https://ssrn.com/abstract=2606744
By Richard Vann