Extraterritorial Taxation #1: How it Has Evolved

SEAT Working Paper Series #2023/1 (June 5, 2023).

12 Pages Posted: 5 Jun 2023

See all articles by Laura Snyder

Laura Snyder

Association of Americans Resident Overseas (AARO); Stop Extraterritorial American Taxation (SEAT)

Date Written: June 5, 2023


This is the first in a series of sixteen papers about the U.S extraterritorial tax system.

Since Cook v. Tait was decided in 1924 much has changed, with respect to both federal taxation and U.S. citizenship. This paper explains their parallel evolutions.

While Cook may hold that the federal government has the power to tax overseas Americans based upon their worldwide income, it is a myth that Cook allows the government to tax individuals under any conditions, without any regard for the effects the policies have, and in manners that violate their rights.

In sum, Cook is ripe for revisiting.

Keywords: Extraterritorial taxtion, Citizenship-Based Taxation, Residence-Based Taxation, Expatriation, Emigration, Overseas Americans, Citizenship, Denationalization, Denaturalization

JEL Classification: D36, E62, F22, G21, G23, G28, H24, H25, H30, H87, J26, K34, K37, N41, N42

Suggested Citation

Snyder, Laura, Extraterritorial Taxation #1: How it Has Evolved (June 5, 2023). SEAT Working Paper Series #2023/1 (June 5, 2023)., Available at SSRN: https://ssrn.com/abstract=4464210 or http://dx.doi.org/10.2139/ssrn.4464210

Laura Snyder (Contact Author)

Association of Americans Resident Overseas (AARO) ( email )

4 rue de Chevreuse
Paris, 75006

Stop Extraterritorial American Taxation (SEAT) ( email )

Box 19602, Manulife P.O.
55 Bloor St. W.
Toronto, Ontario M4W 3T9

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