A Simple Regulatory Fix for Citizenship Taxation

On 11 November 2020 the American Expat Financial News Journal published an article about a paper that recently appeared in Tax Notes Federal. The paper is entitled “A Simple Regulatory Fix for Citizenship Taxation.” Its authors are three of SEAT’s co-founders: John Richardson, Laura Snyder and Karen Alpert.

The paper explains the simple regulatory actions that United States Department of the Treasury can take that would, in the absence of legislative change, improve the lives of Americans living overseas and permit the IRS to better focus its limited resources to more effectively administer the U.S. tax system.

In particular, the paper explains how one simple regulatory change would remove the punitive effects of citizenship-based taxation on Americans living overseas who pay taxes in their country of residence, and therefore shouldn’t have to also be filing tax returns and paying taxes in the United States with respect to non-US-sourced income.

The paper is now available outside of a paywall, via SSRN, at this link.

Richardson, Snyder, and Alpert were recently interviewed about the paper by Robert Goulder, senior tax policy counsel with Tax Analysts. The video may be viewed here:


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