Via TaxProf Blog, a new journal article about taxation of U.S. Persons abroad: Prerna Rao, Note, What Would Humphrey Bogart Do?: An Overview of Federal Taxes as They Apply to the International Community of U.S. Nationals, 25 Quinnipiac Probate Law Journal 298 (2012).
It can be downloaded (by subscribers or for a one-off charge) on WestLaw and on LexisNexis; unfortunately there doesn’t seem to be any freely-available version. The author is the president of the Asian Pacific American Law Students Association at Quinnipiac University School of Law. Abstract after the jump.
Humphrey Bogart, sometimes known as Rick Blaine, arrives at the Mohammed V. International Airport near Casablanca, Morocco. Humphrey, who recently acquired a graduate degree in business, was assigned to the Moroccan branch of an American-owned company. His employer specializes in information technology, and has decided to expand its business and develop the market in this country. As the average employee deployed overseas for the first time, Humphrey, in his early thirties, has the time and energy to start his career in this new land.
Humphrey fits the profile of a typical businessman involved in international trade. He will likely fall in love and marry while working. This Note analyzes the various and common tax liabilities incurred by Americans like Humphrey who travel and live abroad for work.
The term “expat” is used throughout this Note when referring to those who have retained their legal nationality and have not renounced their citizenship while living abroad. This term is commonly used to describe any national who spends significant time abroad. The term “expatriate” is used when referring to those individuals who have legally renounced their American citizenship or permanent residency status and live abroad.
I’ll make a visit to a library and see if I can get my hands on a copy. (I have “friend of the Library” status at one of the local universities. This of course gets me a tax deduction where I actually live, but not a U.S. tax deduction. I think they have LexisNexis access.) Anyone else who’s read it, please feel free to chime in with comments.
