TaxConnections LiveStream

We invite you all to join us at TaxConnections Live Stream Event Friday, May 17th 2019. This is a wonderful opportunity for taxpayers and tax professionals to learn from leading experts about the taxation of U.S. citizens worldwide. Their views are certain to have many people talking about this presentation!

John Richardson will present on why citizenship taxation is not justified and Edward Zelinsky will present why it is a justified law of the U.S. government. TaxConnections is proud to introduce these leading experts along with our Moderator William Byrnes who has written numerous international tax treatises on the subject.


It is a TaxConnections complimentary live stream presentation.

John Richardson CBT

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join us on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows:

This is part of a series of post I have written as a run up to the May 17, 2019 Tax Connections discussion about U.S. citizenship-based taxation.

Introducing Jackie Bugnion …

Jackie Bugnion was an important part of “American Citizens Abroad” for many years. She has an unusually nuanced understanding of the problems that citizenship-based taxation inflicts on Americans abroad. She was (and continues to be) a tireless advocate for the principle that the United States must transition to a system of residence-based taxation. When she retired she was the Tax Director at ACA. She was the author of some of the very best articles about citizenship-based taxation.

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John Richardson - Citizenship Based Taxation

Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows:

You are invited to submit your questions in advance. In fact, PLEASE submit questions. This is an opportunity to engage with Homelanders in general and the U.S. tax compliance community in particular.

I hope that this series of posts will give you ideas for questions and concerns that you would like to have addressed in the May 17, 2019 Tax Connections – Citizenship Taxation discussion.

Laura Snyder has graciously contributed four posts of this series. In her series of four posts, she has outlined the origins and requirements of U.S. citizenship-based taxation.

Ms. Snyder grew up in the United States and moved to Europe as an adult. The tone and pain reflected in her writing suggests that she truly identifies as being a citizen of the United States.

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Edward Zelinsky ( Part 5)
  1. Citizenship-Based Taxation and Benefits

Against the background established in the last three Parts, we can now assess the merits of the United States’ practice of taxing on the basis of citizenship, with a particular focus on the United States’ policy of taxing its nonresident citizens on their respective worldwide incomes and assets. In this Part, I evaluate citizenship-based taxation in terms of the benefits associated with U.S. citizenship. Governmentally furnished benefits are a traditional consideration for tax policy and, as we have seen, 130 is the rationale of Cook. However, upon examination, the benefits rationale for citizenship-based taxation proves unpersuasive, both in theory and in practice. The most significant civil and social benefits extended by the U.S. polity are tied to U.S. residence, not to U.S. citizenship.

The strongest benefits argument for citizenship-based taxation is one with which citizenship mavens are most uncomfortable, namely, the Tiebout/purchase characterization of citizenship as a public service purchased through tax payments. However, even that approach cannot be squared with the current system, which in practice charges different tax prices (often radically different tax prices) for the identical benefits of U.S. citizenship, depending upon the level and kinds of taxes assessed by the nation in which a U.S. citizen resides and earns his income.

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TaxConnections is privileged to announce the upcoming event on Citizenship Taxation will be hosted by William Byrnes of Texas A&M University, College Station, Texas. Our very distinguished speakers are John Richardson of Citizenship Solutions in Toronto, Canada and Edward Zelinsky of Cardozo School of Law in New York, New York. Mr. Zelinsky will speak in support of Citizenship Taxation and Mr. Richardson will speak out against Citizenship Taxation. Given the large number of expatriates who come to TaxConnections to discuss and seek answers to questions on FATCA and Citizenship Based Taxation, we are delighted to have these legal experts educate our expatriate and tax professional audience.

The Future of Citizenship Taxation

Citizenship Taxation: Is It Morally Justified Or Unjustified?

The future of Americans Abroad is greatly impacted by Citizenship Taxation. You are invited to a livestream YouTube event hosted by TaxConnections with two highly educated and distinguished lawyers discussing their position on Citizenship Taxation.

Date: Friday, May 17th
Time: 2:00PM EST/1:00PM CT/12:00PM MT/ 11:00AM PST
(World Time Zones)
Hosted By: TaxConnections – Meet The Experts
Moderator: William Byrnes
For Citizenship Taxation: Edward Zelinsky
Against Citizenship Taxation: John Richardson

Get A Great Education… It’s Free!




Edward Zelinsky ( Part I)

ABSTRACT: The United States’ worldwide taxation of its citizens is less different from international, residence-based norms than is widely believed and is sensible as a matter of tax policy. An individual’s citizenship is an administrable, if sometimes overly broad, proxy for his domicile, his permanent home. Both citizenship and domicile measure an individual’s permanent allegiance rather than his immediate physical presence. Because citizenship and domicile resemble each other, and because other nations often define residence for tax purposes as domicile, the U.S. system of citizenship-based taxation typically reaches the same results as the residence-based systems of these other nations, but reaches these results more efficiently by avoiding factually complex inquiries about domicile.

In contrast, the traditional justification of U.S. citizenship-based taxation, the putative benefits of such citizenship, is not persuasive. In this context, three models of U.S. citizenship are relevant, namely, the minimalist model, the psychological model, and the Tiebout/purchase model. None of these models justifies the worldwide taxation of U.S. citizens on a benefits basis. Rather, such taxation is persuasive because of administrative considerations, i.e., the close resemblance of domicile and citizenship that makes the latter an administrable proxy for the former.

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Lets Debate

TaxConnections CEO Kat Jennings is happy to announce that both John Richardson and Edward Zelinsky have agreed to present their views on Citizenship Taxation on a live stream YOUTUBE event on Friday, May 17th 2019. The mission of this presentation is to provide both sides of the views on Citizenship Taxation.

We have asked the following question to both speakers:

“Should The United States Impose Worldwide Taxation And Reporting On People Who Are Residents Of Other Countries?”

TaxConnections Mission In This Livestream Presentation:

1. Presenting two opposing perspectives on FATCA compliance.

2. Educate taxpayers and tax professionals on FATCA and Foreign Assets.

3. Receive input and perspective from taxpayers and tax professionals.

4. Educate U.S. Congressional Representatives on the impact of FATCA.

5. Provide ideas and solutions to fix the problems associated with Citizenship Taxation on those who do not reside in U.S.

Please register for a complimentary invitation and updates on this very important and educational event for all. You can help us by sharing this blog post with everyone you know who may be affected by Citizenship Taxation or who want to learn from two leading experts on the subject.

Register Here For Complimentary Invitation To Watch Live Stream



John Richardson, Citizenship Based Taxation

The uniquely American practice of “imposing direct taxation on the citizen/residents of other nations” (“citizenship-based taxation”) has NO identifiable group of supporters (with the exception of a few academics who have never experienced it and do not understand it).

The Uniquely American practice of imposing direct taxation on the citizen/residents of other nations has large numbers of opponents (every person and/or entity affected by it). In addition to the submissions of Jackie Bugnion, “American Citizens Abroad“, “Democrats Abroad“, Bernard Schneider there is significant opposition found in the submissions of a large number of individuals. It is highly probable that the submissions come from those who are attempting compliance with the U.S. tax system.

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Expats are America’s global front-line ambassadors. Everyday, their actions and attitudes help shape others’ perceptions of the U.S. and Americans.

They are also the 21st century pioneers, forging opportunities and lives away from our shores and in the wider world.

However far from the U.S. they venture though, they remain in the strange situation of having to file taxes twice, in the country where they live, as well as to the U.S. This is because the U.S. operates a citizenship based taxation system.

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The United States is “making noises” about “tax reform”. Senator Orrin Hatch requested submissions from “stake holders” on what should be included in tax reform. He has clearly received (as did the Ways and Means Committee in 2013 and the Senate Finance Committee in 2015) many suggestions advocating the repeal of “citizenship-based taxation”.

As noted at a site compiling the submissions of those affected by U.S. extra-territorial taxation: Read More

John Richardson

I commented on an article titled: “Why is the IRS Collecting Taxes for Denmark?” which appeared at the “Procedurally Speaking” blog. The article is about the “assistance in collection” provision which is found in 5 U.S. Tax Treaties (which include: Canada, Denmark, Sweden, France and the Netherlands). I am particularly interested in this because of a recent post at the Isaac Brock Society.

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Interview with – Citizenship based taxation, PFIC, the S. 877A Exit Tax and #Americansabroad

On May 22, 2015 I was interviewed by Gordon T. Long. There is NO way to discuss U.S. “citizenship taxation” (which is primarily “place of birth taxation”) without discussing the S. 877A Exit Tax rules. During the month of April 2015, I wrote a 14 part series on “How the S.877A rules affect Americans abroad“. The interview with Mr. Long serves as a good reminder (or if you don’t want to read the posts) on:

– what it means to be a “covered expatriate

how the U.S. S. 877A “Exit Tax” rules operate to impose punitive “taxation” on non U.S. pensions (See the actual Read More