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I thought it would be interesting to have AI create a podcast of Professor Edward Zelinsky’s 2024 paper titled:

Defending U.S. Citizenship-Based Taxation in Theory and in Practice: An Essay on Fiscal Citizenship in a FATCA World

Here is the AI description:

“Defending Citizenship-Based Taxation in a FATCA World

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The provided text is an academic essay arguing in favor of the United States' citizenship-based taxation of its citizens living abroad, justifying it through the concept of "fiscal citizenship," which asserts that membership in a political community entails a duty of tax support. The author contends that the U.S. system is more administratively efficient and less unique or harsh than critics claim, pointing out that other nations like Canada, Australia, and the U.K. achieve similar worldwide taxation results via complex residence and domicile rules. Furthermore, the essay discusses how U.S. tax treaties and the Foreign Account Tax Compliance Act (FATCA) mitigate some problems for overseas citizens and argues that the generous Section 911 exclusion for foreign earned income makes the U.S. system uniquely taxpayer-friendly compared to other nations. Ultimately, the piece frames the debate as a fundamental disagreement over whether U.S. citizenship is a "one-way street" granting rights without corresponding duties.”



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