Many countries seek to encourage retirement savings for their residents by offering tax preferences for privately-operated "qualified retirement plans." These tax preferences generally take the form of delaying taxation of contributions made to the plan and of the earnings thereon until funds...

As the global mobility of workers increases, more and more foreign nationals participate in U.S. retirement plans and eventually receive payments from these plans. The current system for U.S. taxation of these payments is exceedingly complex and uncertain. An elderly recipient of these payments...

Taxation of the worldwide income of U.S. citizens has been a feature of the U.S. income tax since the Revenue Act of 1913. This Article proposes that the United States abandon its imposition of income tax based on citizenship and institute a new system for taxing individuals based solely on...