SEAT Working Paper Series - Extraterritorial Taxation #15 - Taxing in Respect of Rights

PREP Podcaster - ”Success Favours The PREPared Mind”

April 29, 2024 - Participants include:

Dr. Karen Alpert - @FixTheTaxTreaty

Dr. Laura Snyder - @TAPInternation

John Richardson - @Expatriationlaw

The purpose of SEAT has been and continues to be to conduct research (including the SEAT survey), prepare position papers, make submissions by SEAT to various governments, facilitate advocacy by individuals impacted, file amicus briefs and provide a centre for educating interested parties about the U.S. extra-territorial tax regime. (SEAT's work may be found on the SEAT website.)

SEAT believes that the problems caused to Americans abroad by the U.S. extraterritorial tax regime can be ended ONLY by severing citizenship from tax residency. We encourage the United States to join the rest of the world by taxing individuals on the basis of residence and source and NOT based on the citizenship of an individual.

Part of SEAT's work has been break our research into specific issues and categories. These categories are expressed as "SEAT Working Papers". In order to make the "SEAT Working Papers" available in podcast form, SEAT co-founders Karen Alpert, Laura Snyder and John Richardson are developing a series of podcasts - featuring interactive discussion - where we distill the "working paper" into conversational format. It is our hope that these podcasts will make SEAT's content available to a larger group of people.

SEAT Working Paper Series #2023/15 Extraterritorial Taxation #15: Taxing in Respect of Rights

This paper: (1) cautions against any new U.S. tax system that would perpetuate the constitutional and human rights violations of the current system, (2) explains how other countries are able to further the legitimate purpose of preventing tax abuse while also respecting fundamental rights, and (3) describes the salient features of the right system for the United States.

Available at: https://ssrn.com/abstract=4466241.

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AI Description:

"In this engaging podcast, we delve into the pressing topic of extraterritorial taxation in a comprehensive overview of 'Taxing in Respect of Rights', the fifteenth installment of the Seat Working Paper Series. Joined by internationally based experts, we dissect the potential switch from citizenship taxation to the controversial concept of "Residence-Based Taxation." This episode explores the fear and reluctance towards this replacement, shedding light on alleged misconceptions and bringing to fore the unique set of issues faced by Americans overseas due to systemic disconnects and loopholes in the tax system.

We take up the dialogue around citizenship-residency correlation errors and their inherent systemic misrepresentations. We emphasize the need for Americans to normalise the idea of their fellow citizens living abroad. The discussion expands to trace the roots of extraterritorial taxation issues and probes into potential legislature proposal flaws, along with possibilities of misconduct within the IRS.

While dissecting the taxation bias towards Americans abroad, we value the need for a complete disconnection between citizenship and taxation. In our diverse conversation, we traverse through tax complications around U.S. citizenship, contrasting it with global practices, and analyze how U.S. tax laws might impose needless constraints on global citizens.

As the discourse intensifies, we illuminate the significant differences in dual and single U.S. citizenship rules, exploring the subtly embedded system of privilege and disparity in U.S. tax policies. We also unravel the historic role of U.S. citizenship, highlighting the arduous challenges faced by dual citizens in the contemporary era owing to outdated legislative constructs.

Our conversation reaches a climactic conclusion as we call for a long-overdue end to the American system of extraterritorial taxation, advocating for a fair and balanced system where citizenship and tax residency are dissociated. With a wealth of information available on seatnow.org, join us in exploring the complexities of 21st-century taxation issues in a globalized world."