How can US Government impose income tax of US citizens in the oversees only in one country at a time ?
Dear Mr. John Richardson
Proposed Pillar 3 For International Tax Reform: Individuals Should Be Tax Residents Of Only One Country At A Time
This must be an ideal tax policy if this tax reform can be realized.
US Government is adopting US citizenship-based taxation principle
Based on this principle US IRS imposes income tax on oversees income of US citizens staying in the oversees
However, it has been international taxation practice so far that the resident countries of those US citizens are imposing tax also on the same income of the US citizens realized or earned in those resident countries. And income tax aid in resident countries were deducted from US taxation
Besides, US Government has given up taxation of income in the resident countries by adopting special system such as ‘Savings Clause” in order to apply Tax Residents of Only One Country at
In the end It looks like that US Government is thinking a new multilateral agreement which would establish the principle that individuals can be a tax resident of only one country at a time.
Therefore, this Tax Reform plan should be reviewed and accepted by international body involving international taxation such as OECD and between citizenship countries and resident countries reciprocally.
In that occasion it will be a serious issue how to decide, the only one resident country to be, assessing tax on income earned in the resident countries at a time and on what basis.
Do you think this Tax Reform Plan will be possible? In addition, if the answer is “yes”, on what basis the only One Resident country will be decided.
Kook Hee Lee