Citizenship Taxation

72 Pages Posted: 17 May 2015 Last revised: 16 Jun 2016

Ruth Mason

University of Virginia School of Law

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

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:

Ruth Mason (Contact Author)

University of Virginia School of Law ( email )

580 Massie Road
Charlottesville, VA 22903
United States

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