US Citizenship Based Taxation

U.S. Citizenship Based Taxation – Proposals for Reform

See, Co-author. “Tax Simplification: The Need for Consistent Tax Treatment of All Individuals (Citizens, Lawful Permanent Residents and Non-Citizens Regardless of Immigration Status) Residing Overseas, Including the Repeal of U.S. Citizenship Based Taxation,”  by Patrick W. Martin and Professor Reuven Avi-Yonah, September 2013.

Executive Summary

This paper proposes to eliminate the U.S. citizenship based taxation and create a consistent exit tax system.  The complex web of the current U.S. tax law has made it nearly impossible for all but the most sophisticated U.S. citizens and lawful permanent residents (“LPRs”) residing overseas to file complete and accurate tax returns. The proposal should bring consistency, tax simplicity for taxpayers residing outside the U.S., and do so in part by eliminating the U.S. citizenship based tax system, which is unique in the world, dates to the civil war and is inappropriate for the global world we live in.

A Global Perspective on Citizenship-Based Taxation

Vol 38, Issue 2, 2017 (Michigan Journal of International law)

Allison Christians (McGill University)

See, Citizenship based taxation and related reporting requirements:
Problems and suggested solutions, by Heitor David Pinto,

Presented on March 18, 2013
To: Ways and Means Committee, International Tax Reform Working Group
Subject: International taxation of individuals

Revisiting the Tax Treatment of Citizens Abroad: Reconciling Principle and Practice

16 Fla. Tax Rev. 117 (2014)

Michael KirschNotre Dame Law School

The Tax Code as Nationality Law

Michael KirschNotre Dame Law School

Montano Cabezas, Reasons for Citizenship-Based Taxation?,

121 Dick. L. Rev. 101 (2016).
Available at: 

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