US Citizenship Taxation and International Law Violations
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This source material critically examines United States citizenship-based taxation and its potential conflict with international law, particularly as it applies to individuals residing in other countries. The author argues that this form of taxation, which claims non-resident citizens as U.S. tax residents solely based on citizenship, likely violates customary international law (CIL) by contravening established norms of tax residency tied to physical presence or economic connection. The discussion covers the failure of FATCA litigation to address this underlying issue, the unique nature of U.S. tax treaties with their "saving clause," and the implications for national sovereignty and individual human rights, specifically the right to renounce citizenship without undue burden. Ultimately, the author proposes that the U.S.'s practice of citizenship taxation represents an outdated approach out of step with modern international tax principles.
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