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...

American emigrants face many consequences from the extraterritorial application of U.S. taxation and banking policies. Their names, addresses, and Social Security numbers are collected, placed on lists of “suspected U.S. persons,” and submitted to a “Crimes Enforcement Network.” They...

The U.S. extraterritorial tax system has evolved such that today it is more consequential than one century ago. The system, conceived in the stigmatization of overseas Americans, consists of highly penalizing taxation and banking policies that make it difficult for overseas Americans to live...

A recent IRS working paper on the wealth of U.S. persons held outside the United States confirms that overseas Americans are not "fat cats." Rather, they are ordinary people with ordinary income and wealth

This is the second in a series of sixteen papers about the U.S. extraterritorial tax system.This paper summarizes the findings of three recent surveys conducted to better understand how overseas Americans experience U.S. extraterritorial taxation.The three surveys discussed in this paper expose...

This is the third in a series of sixteen papers about the U.S extraterritorial tax system.This paper describes the efforts of many different organizations and individuals to change to the U.S. extraterritorial tax system, to lessen its burden on overseas Americans

This is the eighth in a series of sixteen papers about the U.S extraterritorial tax system.The U.S. extraterritorial tax system violates the 14th Amendment’s equal protection clause in multiple ways. This eighth paper in the series examines two of those ways, demonstrating that the system is...