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 tenth in a series of sixteen papers about the U.S extraterritorial tax system.The U.S. extraterritorial tax system violates multiple provisions of international human rights instruments that have been signed, or signed and ratified, by the United States. The rights in question...

This is the twelfth in a series of sixteen papers about the U.S extraterritorial tax system.Overseas Americans pay taxes in thecountries where they live. Most owe no U.S. tax.The U.S extraterritorial tax system is not about paying taxes, not for overseas Americans and not for the United States....

This is the fourth in a series of sixteen papers about the U.S extraterritorial tax system.Millions of persons living overseas suffer under the U.S extraterritorial tax system. Many organizations and individuals have been and continue to work to change the system. But to date their efforts have...

This is the first in a series of sixteen papers about the U.S extraterritorial tax system.Since Cook v. Tait was decided in 1924 much has changed, with respect to both federal taxation and U.S. citizenship. This paper explains their parallel evolutions. While Cook may hold that the federal...

This is the fifth in a series of sixteen papers about the U.S extraterritorial tax system.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...

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...