Home » Articles » A Coherent Policy Proposal for U.S. Residence-Based Taxation of Individuals

A Coherent Policy Proposal for U.S. Residence-Based Taxation of Individuals

PDF · Cynthia Blum & Paula N. Singer · Jul-23-2012 · 41 VAND. J. TRANSNAT'L L. 705 (2008)

Taxation of the worldwide income of U.S. citizens has been a feature of the U.S. income tax since the Revenue Act of 1913.  This Article proposes that the United States abandon its imposition of income tax based on citizenship and institute a new system for taxing individuals based solely on residence.  This includes (1) a revised definition of “residency status” that would be based on physical presence and be monitored through an entry-exit system, (2) a proposal for an exit tax imposed on termination of residence with respect to unrealized appreciation accrued during the period of residence, and (3) new transitional treatment of residents who have left the United States within the past three years but have not yet made a decision to break off residential ties.  These proposed rules are designed to achieve more uniform compliance, to reduce the administrative burden for U.S. taxpayers, and to facilitate IRS efforts to enforce U.S. tax obligations.




Leave a Reply

ExpressO Top 10 Law Review

ANNOUNCEMENTS

May 2018 Issue on the Second Israel Defense Forces International Conference on the Law of Armed Conflict. Read more about the Journal’s May 2018 issue here.

Thank you to everyone who attended the Journal’s 50th Anniversary celebration on October 5, 2017! View photos from the event here and read about the Journal’s history here.

Connect with the Vanderbilt Journal of Transnational Law on LinkedIn.

The Journal is pleased to listed as the #5 International Law Journal by the 2017 Washington and Lee Law Journal Rankings.

The Journal is pleased to announce the 2017-2018 Board of Editors: here

The Journal is very excited about the success of our February 2017 Symposium, “Sovereign Conduct on the Margins of the Law.” Read more about our February 2017 Symposium here

Please join us in congratulating the Vanderbilt Journal of Transnational Law 2017-2018 Write-On Competition Winners.

Video is available from the Vanderbilt Journal of Transnational Law’s 2015-2016 SymposiumThis is Not a Drill: Confronting Legal Issues in the Wake of International Disasters. Watch here.

Explore Other Vanderbilt Law Resources