Extraterritorial Taxation #16: Cook is Ripe for Revisiting

Abstract

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

This paper contains three concurrent timelines detailing the step-by-step expansion of U.S. extraterritorial taxation as well as of citizenship and equal protection, since the 1924 U.S. Supreme Court decision Cook v. Tait. These timelines underscore how Cook is ripe for review.

Keywords: Extraterritorial Taxation, Citizenship, Equal Protection, FBAR, FATCA, Expatriation, Exit Tax, IRS, Human Rights

JEL Classification: D63, E62, F22, F53, F54, G28, H24, H25, H26, H30, J48, J68, K33, J34, K37, N41, N42