Would Residence-Based Taxation Break the Bank?

Tax Notes International, May 16, 2022, pp. 973-979

Would Residence-Based Taxation Break the Bank? by Robert Goulder
'I’m banging the drum for revenue neutrality. RBT need not break the bank. As of last month, we have analytical confirmation. It arrived courtesy of a study performed by the District Economics Group LLC (DEG), a nonpartisan economic consulting firm. The DEG study goes deep into the money question, examining whether it’s possible for RBT to be revenue neutral. Spoiler alert: Of
course it’s possible.'
'DEG’s computational model was applied to a so-called vanilla approach to achieving RBT, developed by American Citizens Abroad (ACA), a nonprofit membership organization that represents the interests of U.S. citizens living overseas. The primary architect of the approach is tax attorney Charles M. Bruce, a former practitioner with substantial experience in navigating the U.S. international regime. Bruce previously worked in government, academia, and law firms. These days he serves as ACA’s legal counsel, splitting his time between Washington and London.

DEG’s analysis was prepared for ACA’s sister organization, the American Citizens Abroad Global Foundation, a tax-exempt charitable organization. The study is a timely update on an earlier report the group prepared for ACA in 2017, which predated enactment of the Tax Cuts and Jobs Act. Over the last five years, ACA has modified details of its approach to stay current with the post-TCJA environment. DEG’s new study reflects these changes. It also reflects the realities of the COVID-19 pandemic, which has had a chilling effect on the movement of people.'