JC has spotted this. Allison Christians welcomes comments on her work in progress.
Allison supports incremental changes, as she’s convinced that the US is incapable of going right to RBT. I believe that if US legislators are capable of seeing how it should make it easy for people like Tina to exit the system, it will realize that there’s something really wrong in preferring taxpayers over citizens.
Monday, January 18, 2016
Uncle Sam Wants…Who? At UBC Law This WeekThis week I will be in Vancouver to present a paper at the UBC Allard School of Law. The paper, “Uncle Sam Wants…Who? A Global Perspective on Citizenship Taxation,” is now available in draft form on SSRN. Here is the abstract:
Across the globe, banks are flagging accounts with indicia indicating their owners may be “US Persons,” making it possible for the United States to enforce its taxation of nonresident citizens extraterritorially for the first time in history. The indicia method constitutes a mining expedition for US citizens carried out by foreign banks and governments. Establishing a tax jurisdiction in this manner is unprecedented and has significant practical and normative consequences. In the case of so-called “accidental Americans,” it violates one of the most fundamental and universally- acknowledged tenets of taxpayer rights, namely, the right to be informed about what the law requires. Third party indicia-searching should be universally rejected as a means of identifying a taxpayer population. Instead, the United States itself is responsible for cataloguing, informing, and educating its global population of taxpayers. Those who don’t belong in the system should be allowed to opt out without cost.
I welcome comments on this work in progress.