[ad_1]
Monday, July 10, 2023
Snyder: Can Extraterritorial Taxation Be Rationalized?
Laura Snyder (President, Cease Extraterritorial American Taxation (SEAT); Board of Administrators, Affiliation of People Resident Abroad (AARO)), Can Extraterritorial Taxation Be Rationalized?, 76 Tax Regulation. 535 (2023):
There exist a number of rationales for the U.S. extraterritorial tax system. The rationales search to elucidate why abroad People ought to be topic to worldwide taxation by america.
This paper challenges these rationales: The allegiance rationale is outmoded and rejected by the U.S. Supreme Court docket; the advantages rationale has been discredited; the membership in U.S. society rationale is belied by the exclusion of abroad People from important useful elements of the U.S. financial system, the U.S. tax system, and federal help; the “definitely worth the tax value” rationale disregards human rights and the realities of renunciation of U.S. citizenship; and the administrability rationale ignores that the administration of an extraterritorial tax system requires sources past these required to find out domicile — sources the IRS doesn’t have.
Finally, all of the rationales are theoretical. They don’t confront the fact of the particular extraterritorial tax system in place immediately. They don’t take care of the complete scope and complexity of the particular system, or the system’s multitude of intractable issues and injustices.
https://taxprof.typepad.com/taxprof_blog/2023/07/snyder-can-extraterritorial-taxation-be-rationalized.html
[ad_2]