Constitutionality of Citizenship-Based Taxation

8 Pages Posted: 10 Jan 2017 Last revised: 13 Jan 2017

Date Written: January 8, 2017


Citizenship-based taxation (CBT) is the imposition of taxes by a country on income not generated there, or on assets not located there, from an individual who does not live there, only because the individual is defined as a citizen of the country. This essay argues that CBT violates the US constitution as a form of invidious discrimination, based on precedents.

Keywords: taxation, citizenship, nationality, due process, equal protection

Suggested Citation

Pinto, Heitor, Constitutionality of Citizenship-Based Taxation (January 8, 2017). Available at SSRN: or

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