Justification for taxing #americansabroad based on 150 year old justification dating back to civil war. US time warp! renounceuscitizenship.wordpress.com/2013/01/05/coo…
— U.S. Citizen Abroad (@USCitizenAbroad) January 11, 2013
Excellent paper discussing citizenship-based taxation by Professor Avi-Yonah:
This short but well written paper completely dismantles both the Cook v. Tait rationale (Government benefits the citizen wherever the citizen is) and the Zelinsky rationale (that citizenship is a proxy for domicile). Should be read by all.