In Part I, I argued that the benefits rationale – in terms of the public benefits received by citizens – was an unpersuasive justification for the U.S.’s system of worldwide taxation.
I continue my rant in Part II, examining the practical effects of worldwide taxation on non-resident U.S. citizens. Through a labyrinth of “credits, deductions, exclusions, and non-deductibility,” the Internal Revenue Code treats similarly situated U.S. citizens who live abroad differently. How so? Such persons pay different U.S. taxes depending upon the types and amounts of the taxes imposed by the countries in which they live.