Introduction – Why FATCA Litigation Fails …

(Well, most of the time!)*

In September of 2024, I wrote a blog post about FATCA litigation.

Q. Why Does FATCA Litigation Fail? A. Because, It Focuses On The Symptom And Not The Cause

That post was discussed on an IRS Medic podcast here:

In that post, I suggested that FATCA litigation fails because it has to date focused on certain results of FATCA (privacy breaches, discrimination, etc.) No FATCA litigation (to date) has focused on the reality that U.S. “citizenship taxation” is the reason for FATCA and therefore the cause of all the FATCA related problems. The effect of FATCA and the FATCA IGAs is to enforce U.S. citizenship taxation on the world (including and PRIMARILY on individuals who are tax residents of other countries). A principal purpose of FATCA is to export U.S. tax laws into other countries. By signing the FATCA IGAs, these countries agree to assist the United States in identifying which of their country’s residents (and often citizens) are also U.S. citizens and should therefore be subject to U.S taxation. Put another way: the purpose of the FATCA IGAs is to expand the U.S. tax base into other countries.

For background on the issue of the United States claiming the residents of other countries as U.S. tax residents see:

The Issue Is Not @CitizenshipTax. The Issue Is Whether The US Can Claim The Tax Residents Of Other Countries As US Tax Residents!

The conclusion of the September 2024 post was that:

Future FATCA litigation should focus on whether it is a violation of international law for the United States to impose citizenship taxation (the reason for FATCA) on the residents of other countries (who suffer the effects of FATCA).

The purpose of this post is to continue the analysis and to explore the specific question:

Is U.S. citizenship taxation – the process of claiming nonresidents as U.S. tax residents – a violation of international law?

Is it a violation of international law for the United States to:

1. Claim the residents of other countries as U.S. tax residents; and

2. Impose U.S. taxation on the non-U.S. source income of those individuals who do NOT live in the United States?

(I am introducing and developing the argument cannot impose U.S. citizenship taxation on the tax residents of OTHER countries. The United States, has of course the sovereign right, to impose citizenship taxation on U.S. residents.)

If U.S. citizenship taxation, as applied to the residents of OTHER countries, conflicts with the norms of international law, then the foundation for FATCA (as applied to non-U.S. residents) crumbles. In theory, this would provide courts and tribunals a justification for refusing to apply FATCA obligations in relation to individuals who are tax residents of other countries and are not residents of the United States. In addition, it might cause countries to give careful consideration to the effects of the “saving clause” which is part of all U.S. tax treaties.

How U.S. Citizenship Tax, The Treaty “Saving Clause” and FATCA Create A Fiscal Prison For Dual Tax Residents

It is my hope that this post will analyze this question by identifying and outlining “some” of the relevant issues. Perhaps, this post will “begin’ a discussion about this important issue. Should U.S. citizens, because and only because of their citizenship, become “dual tax residents” simply by moving from the United States?

For each issue I will suggest an answer and provide a backup source(s) for further inquiry.

Suggested conclusion:

This post is a “thought experiment”. I believe that a credible argument can be developed that U.S. citizenship taxation – as applied to those who are tax residents of other countries – is a violation of CIL (“Customary International Law”). What follows are the “individual components” of the argument, along with commentary on each. The individual components are organized in the following outline:

Outline

Part A – Some Theoretical Concepts

1. What is US citizenship taxation? U.S. citizenship taxation defined

2. What is meant by international law?

Part B – Tax Residency And International Law

3. Is the concept of “tax residency” generally subject to the rules of international law?

4. Concepts of tax residency as expressed through tax treaties including treaty tie breakers

Part C – Can The Method Of Taxation Violate Individual Rights As Expressed In Human Rights Documents?

5. Professor William Thomas Worster – Taxation and Human Rights

6. Barriers To Emigration Under International Law

Part D – U.S. Citizenship Taxation And the Tax Sovereignty Of Other Nations

7. U.S. Citizenship Taxation As A Method To Siphon Capital From Other Nations

8. The Common Law Revenue Rule As An Expression Of Tax and Territorial Sovereignty

Part E – U.S. Tax Treaties And The “Saving Clause” – Contracting Out Of The Principles Of International Law?

9. Taxation Perspective: Is the “saving clause” an agreed upon override to the “revenue rule” and other international norms?

10. Information Perspective: Can FATCA information extraction generally be used to refuse to provide information about a country’s tax residents?

11. Enforcement Perspective: Should exemptions from cooperation on enforcement of tax debts extend to the disclosure of FATCA information? The cases of Canada, Netherlands, France, Sweden …

Part F – Possible Conclusions …

For those who don’t want to read the rest:

The purpose of this post has been to develop a general theory of why U.S. citizenship taxation – to the extent that it claims the tax residents of other countries as U.S. tax residents – is a violation of international law. Theory aside, there is no other country in the world that uses an attribute (citizenship), that is often an immutable characteristic (place of birth), that bears no presumptive relevance to a physical or economic connection to a country, as a sufficient condition for tax residency. In so doing, the United States is defining tax residency in terms of the “circumstances of birth”, rather than the “circumstances of life”. The only effect is to claim the residents of other countries as tax residents of the United States (even when they are residents and often citizens of those other countries).

It is respectfully submitted that, for these reasons, that citizenship taxation is a violation of CIL (“Customary International Law” and should NOT be tolerated by the international community.

In developing my argument, I have included links to previous posts. The linked posts are NOT part of this post, but are supplied for further reading on each topic.

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Part A – Some Theoretical Concepts

1. What is US citizenship taxation? How should U.S. citizenship taxation be defined?

As I have developed in other posts …

Therefore, the practical meaning of “citizenship taxation” is the United States imposing taxation on the non-US source income earned by people who live in other countries. To be clear: citizenship taxation means that the United States is claiming the residents of OTHER countries as US residents for tax purposes!

…

US citizenship taxation means that the US can tax the non-US source income of residents of other countries! – because and ONLY because the person was born in the USA or born outside the U.S. to a U.S. citizen parent! You would be surprised how many people fit that definition.

In practical terms, by defining “Tax residency” in terms of citizenship, the United States is claiming the tax residents of OTHER countries as U.S. tax residents.

The Road To Tax Reform For Americans Abroad: Part 2 – What Is US Citizenship Taxation?

(Interestingly, the IRS confirms this here:

https://www.irs.gov/individuals/international-taxpayers/frequently-asked-questions-about-international-individual-tax-matters)

2. What is meant by international law?

In 2025 all questions are first posed to google. In this case I posed the question:

“meaning of international law”

I received the answers that I expected. The answers focus on the meaning of the law between nations. Examples include:

a body of rules established by custom or treaty and recognized by nations as binding in their relations with one another

and

International law is an independent system of law existing outside the legal orders of particular states. It differs from domestic legal systems …

Combining these two answers, it is reasonable to infer that:

International law is an independent system of law, existing outside the legal orders of a particular state which is based on (1) custom and (2) treaty.

Therefore, we would expect that international tax law would be based on both custom (either written or unwritten rules) and treaty (written rules). That treaties are a body of international tax law is certain. The more difficult (and interesting) question is whether “custom” can become part of international tax law.

Can “custom” become part of international tax law?

Q. Is there such a thing as customary international tax law?

A. In 2019 Professor Rueven Avi-Yonah writes:

Customary international law is law that “results from a general and consistent practice of states followed by them from a sense of legal obligation.” “International agreements create law for states parties thereto and may lead to the creation of customary international law when such agreements are intended for adherence by states generally and are in fact widely accepted.” Does customary international law (CIL) exist in tax? There are over 3,000 bilateral tax treaties, and they are about 80% identical to each other, but do they create CIL that binds in the absence of a binding treaty, like for example the Vienna Convention on the Law of Treaties binds the US, which has not ratified it? This chapter will argue that the answer is yes, using four examples: jurisdiction to tax, the permanent establishment (PE) threshold, the arm’s length standard, and non-­‐discrimination. …

Customary international law is law that “results from a general and consistent practice of states followed by them from a sense of legal obligation.” 2 “International agreements create law for states parties thereto and may lead to the creation of customary international law when such agreements are intended for adherence by states generally and are in fact widely accepted.” 3 Does customary international law (CIL) exist in tax? There are over 3,000 bilateral tax treaties, and they are about 80% identical to each other,4 but do they create CIL that binds in the absence of a binding treaty, like for example the Vienna Convention on the Law of Treaties binds the US, which has not ratified it? This chapter will argue that the answer is sometimes yes, using four examples: jurisdiction to tax, the permanent establishment (PE) threshold, the arm’s length standard (ALS) and non-­ discrimination.

https://repository.law.umich.edu/cgi/viewcontent.cgi?article=1271&context=law_econ_current

To be clear, Professor Avi-Yonah is arguing that “jurisdiction to tax” (which necessarily includes tax residency) can be determined through the evolution of CIL (“Customary International Law”).

Part B – Tax Residency And International Law**

3. Is the concept of “tax residency” generally subject to the rules of international law?

Professor Avi-Yonah uses “jurisdiction to tax” as one of his examples in support of the principle that international tax law can be created by “custom”.

He develops this argument by beginning with the proposition that taxing rights are based on either “residence” or “source”. He then traces the historical evolution of the CFC (“Controlled Foreign Corporation”) rules as evidence that the “jurisdiction to tax” can evolve through international consensus. The evolution of “jurisdiction to tax” by consensus is the creation of CIL “Customary International Law”.

Specifically, on the issue of “Jurisdiction to Tax”, Professor Avi-Yonah writes:

There are two widely accepted bases of jurisdiction to tax: residence and source, which are the tax law equivalents of nationality and territoriality, the two bases of jurisdiction in international law. For a country to have the right to tax income, that income must either belong to a resident, since residents may be taxed on worldwide income, or it must have a source in the taxing country, since a country may tax non­‐residents on income sourced within it.

https://repository.law.umich.edu/cgi/viewcontent.cgi?article=1271&context=law_econ_current

The key point is the conclusion that the jurisdiction to tax can evolve pursuant to CIL (“Customary International Law”. Note that although treaties are not determinative of CIL, they may influence the evolution of CIL.

Question: Can it be argued that residence and source as jurisdictional markers for taxation mean that “citizenship”, without any physical or economic connection, cannot under CIL (“Customary International Law”), be a sufficient condition for tax residency?

There is no necessary connection between citizenship and any of: actual residence, domicile or ordinary residence or economic connection to a country. Also, (as will be noted below), citizenship is the least important criterion in applying tax treaty tie breaker rules!

4. Concepts of tax residency as expressed through tax treaties including treaty tie breakers

Concepts Of Tax Residency

There are three general forms of tax treaties in the world today:

OECD Model Treaty (followed by most of the world) – The definition of Tax Residency does NOT include citizenship.

UN Model Treaty (more applicability to developing countries) – The definition of Tax Residency does NOT include citizenship.

US Model Treaty (only U.S. treaties) – The definition of Tax Residency does include citizenship AND the treaty is heavily based on this. Treaty partners agree to a “saving clause” that allows the U.S. to impose worldwide taxation on the residents of the treaty partner country who happen to be U.S. citizens.

U.S. tax treaties in general and the U.S. Model Tax Treaty in particular are the ONLY tax treaties that:

(1) makes citizenship a sufficient condition for tax residency:

(2) ensure that ONLY U.S. citizens are “dual tax residents” if they move from the United States; and

(3) include a “saving clause” which creates a presumption against U.S. citizens receiving the benefits of U.S. tax treaties.

Significantly, the U.S. tax treaty based disabilities of U.S. citizenship apply to both resident and nonresident U.S. citizens who are tax residents of other countries!

Question: Can it be argued that because the U.S. is the ONLY country that uses citizenship without residence, as sufficient for tax residency, that this is in violation of CIL (“Customary International Law”

Treaty Tie Break

First, the treaty tie breakers are designed to facilitate the international standard of preventing dual tax residency. The saving clause in U.S. tax treaties allows Green Card holders but NOT U.S. citizens to tie break out of tax residency. This is clear discrimination against U.S. citizens based on and only on U.S. citizenship.

U.S. citizens are, because and only because, of U.S. citizenship dual tax residents, when they move from the USA and become a tax resident of another country!

Second, in ALL tax treaties, when dual tax residency is established and a treaty tie break provision applies, “citizenship” is the least important determinant of tax residency! For example, consider the treaty tie breaker provision in the U.S. Netherlands tax treaty:

2. Where by reason of the provisions of paragraph 1, an individual is a resident of both States, then
his status shall be determined as follows:

a) he shall be deemed to be a resident of the State in which he has a permanent home
available to him; if he has a permanent home available to him in both States, he shall be deemed to be a resident of the State with which his personal and economic relations are closer (centre of vital interests);
b) if the State in which he has his centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he shall be deemed to be a resident of the State in which he has an habitual abode;
c) if he has an habitual abode in both States or in neither of them, he shall be deemed to be a resident of the State of which he is a national;
d) if he is a national of both States or of neither of them, the competent authorities of the States shall settle the question by mutual agreement.

https://www.irs.gov/pub/irs-trty/nether.pdf

Put another way:

The United States uses citizenship as a sufficient condition for tax residency. Under tax treaty tie break provisions, citizenship/nationalty is the LEAST RELEVANT criterion to determine tax residency!

Conclusion: U.S. citizens living outside the United States are ALWAYS dual tax residents who can NEVER shed U.S. tax residency without renunciation of U.S. citizenship!

Double Taxation Of Americans Abroad Is Because Of Citizenship Based Double Tax Residency

Question: Does the fact that U.S. citizens are always dual tax residents violate the principle of CIL (“Customary International Law”) that an individual should be subject to ONLY one tax residency at a time?

Question: Can the fact that citizenship taxation is based on a concept of taxation that is 100 years old be used to argue that it is no longer compatible with CIL (“Customary International Law”)?

US Tax Treaties Should Reflect The 21st Century And Not The World Of 100 Years Ago

Conclusion: Tax treaties should evolve according to CIL and reflect the evolution of custom in international law. As a result, US dual tax residency causes by US citizenship taxation should be understood to be in violation of CIL.

Part C – Can The Method Of Taxation Violate Individual Rights As Expressed In Human Rights Documents?

5. Professor William Thomas Worster – Taxation and Human Rights

The original article upon which this podcast is based is here.

https://scholarship.law.slu.edu/cgi/viewcontent.cgi?article=1083&context=lj

6. Barriers To Emigration Under International Law

As Professor Worster notes at page 91:

However, the HRC has held that exit or travel visas do violate the right to leave, even when it is (theoretically) possible to acquire one.56 In addition, burdensome fees or administrative costs applying to exercise this right57 (e.g., passport application fees)58 that go beyond the administrative expense are also violations because they are not necessary.59 In general, the argument that the individual owes the state an obligation has been viewed skeptically because: “As shown by the practice of many States, governments have a keen interest in preventing their working population or certain groups . . . from leaving the country. It is always possible to come up with some sort of ‘debt’ owed the State. . . .”60 In addition to treaty law, we can consider customary international law and its interaction with the right to change nationality.61 In order to determine if a rule exists under customary international law, we have to establish a sufficient amount of state practice with opinio juris.62 When the International Law Commission (“ILC”) has studied this question of a human right to renunciation, it has repeatedly reached the same conclusion that there was a right to renounce.63 The U.N. Secretariat has reached the same conclusion.64 The Institute of International Law as long ago as 1896,65 and the International Law Association as long ago as 1924,66 recognized the right to expatriate. Classic authors of public international law have also argued in favor of a right to renounce nationality as a human right.67 The only restriction the ILC could find on renunciation was to prevent the individual from becoming stateless.68
Suggestions that exit visas might be acceptable were rejected.69 The U.N. Secretariat opined that another possible exception to that right would be individuals subject to a military service obligation.70

https://www.slu.edu/law/law-journal/-pdf/issues-archive/v62-no1/william_thomas_worster_article.pdf

Professor seems to be confirming that the validity of a link between international human rights law, international law and international tax law. This supports the argument that CIL is part of international tax law.

See also:

https://expatriationlaw.substack.com/p/taxation-and-the-human-right-to-renounce

Part D – U.S. Citizenship Taxation And the Tax Sovereignty Of Other Nations

7. U.S. Citizenship Taxation As A Method To Siphon Capital From Other Nations

As the following post describes, the effect of the United States claiming the residents of other countries as U.S. tax residents is to extract capital from that other country to the United States.

The @ADCSovereignty #FATCA lawsuit asks: Is US CBT an exercise of US sovereignty or a violation of Canadian sovereignty

8. The Common Law Revenue Rule As An Expression Of Tax and Territorial Sovereignty

Generally the common law “revenue rule” is a rule standing for the principle that a sovereign country will NOT enforce tax/revenue laws of another country. It is submitted that, at a bare minimum, this should be interpreted to mean that one country cannot arbitrarily claim the residents of another country as its own tax residents. Therefore, in the absence of other considerations, it is submitted that the agreement of a FATCA partner country to assist the United States is imposing U.S. taxation on the residents of the FATCA parter country, would run afoul of the revenue rule.

As Professor Vern Krishna describes it:

A country’s revenue laws reflect its political sovereignty and create property rights that affect relationships. Hence, sovereign states will not enforce the revenue laws of foreign countries and domestic courts will not exercise jurisdiction beyond their national boundaries. This rule, known as the “revenue rule”, is long standing in the common law.

At face value, it would appear that via the FATCA IGAs, the FATCA partner country is assisting the United States in enforcing U.S. tax laws on all U.S. citizens. This means that the the FATCA partner is assisting the United States in enforcing U.S. tax law on:

1. U.S. citizens who are NOT tax residents of the FATCA partner country; and

2. U.S. citizens who ARE tax residents of the FATCA partner country (its own tax residents).

It is reasonable to infer that: To the extent that FATCA assists the United States in imposing U.S. taxation on the residents of the FATCA partner country, this would be a clear violation of the tax sovereignty of that partner country.

To the extent that the common law revenue rule still exists and is CIL, “U.S. FATCA Demands” appear to presumptively violate the principles of the “revenue rule”. Professor Krishna goes on to note that (at least in the pre-FATCA past) U.S. tax treaties have respected the revenue rule. He notes that:

The United States limits extraterritorial collection assistance based on preserving its sovereignty, security, and public policy. For example, Article 26, paragraph 4 of its Model Income Tax Convention, (September 20, 1996) provides:

This paragraph shall not impose upon either of the Contracting States the obligation to carry out administrative measures that would be contrary to its sovereignty, security, or public policy.

However, the United States has several tax treaties with foreign countries that provide for information exchange and, sometimes, limited collection assistance. Paragraph 1 of Article XXVI- A of the U.S.- Canada Tax Convention, for example, provides for limited assistance between the respective tax authorities of the states in collecting a “revenue claim”. The 1995 Protocol requires that a state seeking collection assistance certify that the revenue claim has been “finally determined.”

Krishna – Revenue Rule

https://kpklaw.ca/media/The-Revenue-Rule.pdf

The-Revenue-Rule

Part E – U.S. Tax Treaties And The “Saving Clause” – Contracting Out Of The Principles Of International Law?

9. Taxation Perspective: Is the “saving clause” an agreed upon override to the “revenue rule” and other international norms?

Article 24 – Paragraph 1 of the U.S. Netherlands Tax Treaty:

1. Notwithstanding any provision of the Convention except paragraph 2, each of the States may tax its residents and nationals as if the Convention had not come into effect. For this purpose, as regards the United States, the term national shall include a former citizen or long-term resident, not being a national of the Netherlands, whose loss of such United States status has as one of its principal purposes the avoidance of income tax, but only for a period of 10 years following such loss.

(Note that the treaty defines “nationals” as including “citizens”.)

Because ONLY the United States employs “citizenship taxation” the “saving clause” benefits primarily the United States. Given the contextual context of the “revenue rule” it is reasonable to ask:

“Should the revenue rule be interpreted to deny U.S. citizens who are tax residents of the Netherlands the benefits of the tax treaty? (If the “saving clause” is interpreted to allow the U.S. to tax U.S. citizens who are tax residents of the Netherlands, does this not violate the spirit of the “revenue rule”?

Note that the “saving clause” is understood to allow the United States to deny U.S. citizens who are tax residents of the Netherlands the benefits of the treaty”. The reality of this is accurately described as follows …

This means that: Every country in the world who signs a tax treaty with the United States that includes a “saving clause” is agreeing that the United States has the right to tax income earned in the treaty partner country by residents of the treaty partner country. It is obvious that countries signing these treaties have no idea what they are signing. The problem has been further illuminated by the recent US Croatia tax treaty that allows the United States to imposes taxation on Croation residents who ARE and WERE US citizens.

The Road To Tax Reform For Americans Abroad: Part 2 – What Is US Citizenship Taxation?

10. Information Perspective: Can FATCA information extraction generally be used to refuse to provide information about a country’s tax residents?

On August 29, 2022 the U.S. Government wrote to the Dutch government confirming the intention of the United States to impose U.S. taxation on U.S. citizens who are tax residents of the Netherlands. In addition the United States confirmed the role of FATCA in facilitating this objective.

August 29 Letter From US Treasury To Dutch Government Reinforces Commitment To Impose US Citizenship Tax On Dutch Residents

Can the Dutch government refuse to disclose the FATCA information of Dutch residents on the basis of the U.S. Netherlands tax treaty?

The recitals to the FATCA IGAs confirm that the FATCA IGAs are legitimate as expressions of the information exchange provisions in U.S. tax treaties. For example, Article 32 of the U.S. Netherlands treaty includes a limiting provision as follows:

“Article 32

LIMITATION OF ARTICLES 30 AND 31

1. In no case shall the provisions of Articles 30 (Exchange of Information and
Administrative Assistance) and 31 (Assistance and Support in Collection) be construed so as to
impose on one of the States the obligation:

a) to carry out administrative measures at variance with the laws and administrative
practice of that or of the other State;
b) to supply information which is not obtainable under the laws or in the normal
course of the administration of that or of the other State;
c) to supply information which would disclose any trade, business, industrial,
commercial, or professional secret or trade process, or information, the disclosure of which
would be contrary to public policy.
2. Notwithstanding paragraph 1, the competent authority of each State shall have the
authority to obtain and provide information held by financial institutions, nominees or persons
acting in an agency or fiduciary capacity or information about persons holding interests,
including bearer shares, in another person, regardless of any laws or practices of the State that
might otherwise preclude the obtaining of such information.

https://home.treasury.gov/system/files/131/Treaty-Netherlands-Protocol-3-8-2004.pdf

In light of the revenue rule and in light of CIL understanding that tax residency is based on actual residency and NOT on citizenship:

Is it not contrary to Netherlands public policy to facilitate the bulk transfer of information about its own tax residents (regardless of citizenship) to the U.S. government?

11. Enforcement Perspective: Should exemptions from cooperation on enforcement of tax debts extend to the disclosure of FATCA information? The cases of Canada, Netherlands, France, Sweden ...

There are a small number of countries that:

1. Have provisions that assist the United States in collection with its tax debts, but

2. Deny that assistance in cases where the United States is attempting to collect a tax debt on one of their own citizens.

These treaties are discussed here:

Canada U.S. Tax Treaty – Article XXVIA: How the 5th Protocol Enhances protection for Canadian citizens

Dual Citizens of Sweden, France, Netherlands, Denmark & Canada take note! Your Country WILL NOT Collect for the U.S.

(The above post was cross-posted to the Isaac Brock Society here. The comments on the Brock repost are of interest.)

These treaties appear to be an attempt to preserve the revenue rule in relation to a country’s own citizens.

Is it compatible with these treaties for the United States to insist on FATCA enforcement with respect to a class of taxpayers where collection is prohibited because of a tax treaty?

For example, the U.S. Netherlands treaty includes …

NETHERLANDS

ARTICLE 31
Assistance And Support in Collection

1. The States undertake to lend assistance and support to each other in the collection of the taxes which are the subject of the present Convention, together with interest, costs, and additions to the taxes and fines not being of a penal character.

4. The assistance provided for in this Article shall not be accorded with respect to the citizen, corporations, or other entities of the State to which application is made, except in cases where the exemption or reduced rate of tax granted under the Convention to such citizens, corporations or other entities has, according to mutual agreement between the competent authorities of the States, been enjoyed by persons not entitled to such benefits.

Part F – Possible Conclusions …

The purpose of this post has been to develop a general theory of why U.S. citizenship taxation – to the extent that it claims the tax residents of other countries as U.S. tax residents – is a violation of international law. Theory aside, there is no other country in the world that uses an attribute (citizenship), that is often an immutable characteristic (place of birth), that bears no presumptive relevance to a physical or economic connection to a country, as a sufficient condition for tax residency. In so doing, the United States is defining tax residency in terms of the “circumstances of birth”, rather than the “circumstances of life”. The only effect is to claim the residents of other countries as tax residents of the United States (even when they are residents and often citizens of those other countries).

It is respectfully submitted that, for these reasons, that citizenship taxation is a violation of CIL (“Customary International Law” and should NOT be tolerated by the international community.

John Richardson – Follow me on X.com @ExpatriationLaw

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*Appendix – Retired KLM Pilot Ronald Aries – A Pioneer In FATCA Litigation

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**An excellent and contemporary article about international tax law and CLI (“Customary International Law”)

https://www.law.georgetown.edu/international-law-journal/wp-content/uploads/sites/21/2019/10/GT-GJIL190001.pdf