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https://www.americansabroad.org/old/exit-tax-claimed-to-be-unconstitutional/

Exit Tax Claimed to be Unconstitutional

A lengthy article in the Florida Tax Review by William Thomas Worster of The Hague University, maintains that the “exit tax” imposed on individuals choosing to renounce their American nationality is unconstitutional.

 He argues that a former citizen should fall into the same category as any other nonresident alien, and not be discriminated against on the basis of his/her national origin. “[If] … citizens are engaged in a collective relationship, with the government merely acting as their representative and agent, then when a citizen elects to leave the community and no longer receive the rights of the community, then the individual should not have lingering obligations upon leaving the state.”