• Tax Simplification: The Need for Consistent Tax Treatment of All Individuals (Citizens, Lawful Permanent Residents and Non-Citizens Regardless of Immigration Status) Residing Overseas, Including the Repeal of U.S. Citizenship Based Taxation
  • September 23, 2013 | Author: Patrick W. Martin
  • Law Firm: Procopio, Cory, Hargreaves & Savitch LLP - San Diego Office
  • This paper proposes to eliminate the U.S. citizenship based taxation and create a consistent exit tax system. The exit tax would apply to all long term residents of the U.S. who build up assets and wealth with significant unrealized gains and leave the U.S. to escape taxation. The complex web of the current U.S. tax law has made it nearly impossible for all but the most sophisticated U.S. citizens and lawful permanent residents (“LPRs”) residing overseas to file complete and accurate tax returns. The proposal should bring consistency, tax simplicity for taxpayers residing outside the U.S., and do so in part by eliminating the U.S. citizenship based tax system, which is unique in the world, dates to the civil war and is inappropriate for the global world we live in.