ACA strongly recommends that its members read the article by Bernard Schneider*, published in the Virginia Tax Review, October 1, 2012. It is entitled “The End of Taxation without End: A New Tax Regime for U.S. Expatriates." The full article can be found here .
Mr. Schneider discusses the various justifications that have been put forward for the worldwide taxation of nonresidents and concludes that it is no longer justified. He proposes that the United States eliminate the worldwide taxation of expatriate citizens and green card holders and replace the exit tax on those renouncing US citizenship or relinquishing green card status with a departure tax regime that would apply to all US citizens and green card holders who emigrate from the United States. Mr. Schneider adds a strong voice to those of other legal scholars who have recognized the need for the United States to adopt residence-based taxation. ACA is grateful to see ever increasing support in the academic world for residence-based taxation.
*J.D. and LL.M. in Taxation, New York University School of Law; Ph.D. Candidate, Queen Mary, University of London, School of Law, Centre for Commercial Law Studies.