Don’t Blame the Victims: Individuals and the MRT

A new article by SEAT co-founders Karen Alpert, John Richardson and Laura Snyder was recently published in Tax Notes Federal and Tax Notes International.

The article is entitled “Don’t Blame the Victims: Individuals and the MRT.”

The article’s abstract appears below.

The article is available outside a paywall at this link.



Moore v. United States has garnered a lot of attention. This includes commentary asserting both that (i) few individuals were subject to the Mandatory Repatriation Tax (MRT), and (ii) for the few that were subject to it, they were at fault for any damages they suffered – there were steps they could and should have taken to avoid being subject to the MRT.

The reality is that the MRT had devastating effects for Americans living and operating small businesses outside the United States. This paper: (i) demonstrates that the MRT affected more individuals than multinational corporations, and (ii) explains why there was little that Americans living and operating small businesses outside the United States could have done to avoid the damages inflicted on them by the MRT.

Ultimately, it is time to stop using U.S. tax policies to punish American nationals for living outside the United States, and it is time to stop blaming them for the punishment – such as the MRT – inflicted on them.


One thought on “Don’t Blame the Victims: Individuals and the MRT

  1. So-called tax experts are ignorant of CBT taxation. I believe the reason for this is perverse. Doubling down on “foreign is scamming the system” plays into key congressional players’ ears. They, in turn, invite you to comment on policy. Scholars who favor reducing overseas tax burdens are excluded.

    Below is an excellent demonstration of moral corruption. Senator Kennedy asked a tax expert which American companies are tax cheats, but she could not answer. Check the link:

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