There exist multiple rationales for the U.S. extraterritorial tax system. The rationales seek to explain why overseas Americans should be subject to worldwide taxation by the United States.This paper challenges those rationales: The allegiance rationale is outmoded and rejected by the U.S....

This is the thirteenth in a series of sixteen papers about the U.S extraterritorial tax system.The leaders of some countries are finally understanding that FATCA has devasting effects. Unfortunately, to date few, if any, leaders of other countries have looked beyond FATCA to understand the...

This is the fifteenth in a series of sixteen papers about the U.S extraterritorial tax system.This article:- Cautions against any new U.S. tax system that would perpetuate the constitutional and human rights violations of the current system; - Explains how other countries are able to further the...

This is the last in a series of sixteen papers about the U.S extraterritorial tax system.This paper contains three concurrent timelines detailing the step-by-step expansion of U.S. extraterritorial taxation as well as of citizenship and equal protection, since the 1924 U.S. Supreme Court...

This is the eleventh in a series of sixteen papers about the U.S extraterritorial tax system.Instead of practicing deference, federal courts must subject tax legislation to the same constitutional review to which they subject other legislation.This series of papers demonstrates that the U.S....

This is the sixth in a series of sixteen papers about the U.S extraterritorial tax system.The immediately preceding (fifth) paper in this series explains and refutes the five most commonly offered rationales for extraterritorial taxation. This sixth paper confronts those theoretical rationales...

The United States is the only developed country to practice a system of extraterritorial taxation that treats the tax residents of other countries as simultaneously subject to U.S. worldwide taxation based on citizenship. This extraterritorial tax system is a separate and more punitive tax...

The uniquely American definition of “tax residency,” which includes the imposition of worldwide taxation on the tax residents of other countries, has delegated to the IRS the job of implementing three separate and distinct tax systems: residence, source, and extraterritorial. Through its...

This article explains the simple regulatory actions that United States Department of the Treasury can take that would, in the absence of legislative change, improve the lives of Americans living overseas and permit the IRS to better focus its limited resources to more effectively administer the...