Is the Senate Finance “Punting” on reforming international tax rules for U.S. citizens living overseas?

By Patrick W. Martin · January 22, 2014 · Updated June 20, 2026

Summary of Staff Discussion Draft: International Business Tax Reform

Chairman Max Baucus

U.S. Senate Committee on Finance

11/19/13

http://www.finance.senate.gov/imo/media/doc/Chairman’s%20Staff%20International%20Discussion%20Draft%20Summary.pdf

“The staff discussion draft does not address the international tax rules addressing individuals, whether for U.S. citizens living overseas or foreign nationals moving to the United States. The Chairman’s staff is considering reforms to simplify the rules in this area while appropriately taxing such individuals. Comments are requested regarding the scope and mechanics of reforms in this area.”

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Patrick W. Martin

U.S. International Tax Lawyer · Shareholder, Chamberlain Hrdlicka

Patrick W. Martin is a U.S. tax lawyer licensed in California, Texas, and Washington, D.C., with 32+ years advising on the tax consequences of renouncing U.S. citizenship or abandoning lawful permanent residency. He served as lead counsel in Aroeste v. United States, the landmark federal case on green card holders, tax treaties, and the exit tax. Best Lawyers in America® (Tax Law), 2015–2025.

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Is the Senate Finance “Punting” on reforming international tax rules for U.S. citizens living overseas?

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