Separating Citizenship From Tax Residency: The Republicans Overseas Tax Proposal

In 2024 the Republicans Overseas Tax Committee created the following proposal for separating U.S. citizenship from U.S. tax residency. The proposal is three parts which are:

1. A Legislative Fix – changing who is a tax resident from “individual” to “resident”.

2. A Regulatory Fix – changing the regulation to define “individual”in the Internal Revenue Code to mean “resident”

3. A Treaty Fix – narrowing the range of the treaty “saving clause” so that U.S. citizens who are tax residents of other countries can use the “treaty tie break” provision to be treated as nonresidents.

Ending the Unjust Taxation of Overseas Americans

A September 2024 twitter discussion of the proposal is here along with a link to a series of videos made by John Richardson and James Gosart:

John Richardson – Follow me on X.com @ExpatriationLaw

One thought on “Separating Citizenship From Tax Residency: The Republicans Overseas Tax Proposal”

  1. GregS

    This would be a huge historical event requiring an annual national holiday (for expats)!! Pray that God’s brings forth an end to citizenship based taxation!!

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