Tag Archives: Laura Snyder

A Simple And Unilateral Fix For Citizenship Taxation – Richardson, Snyder and Alpert – Join Us On October 8, 2025

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A Simple Tax Treaty Fix To Citizenship Taxation

The problem of citizenship taxation for Americans abroad is acute. Many people agree that citizenship taxation must end. Citizenship taxation is a combination of the U.S. Internal Revenue Code (imposing punitive taxation on non-U.S. assets and income streams), Regulations (the Internal Revenue Code gives Treasury broad regulatory authority) and tax treaties (the treaty “saving clause” denies U.S. citizens most of the benefits of the tax treaties. Unsurprisingly, various remedies have been proposed.

Legislative Fix (a change to the Internal Revenue Code):

Examples of proposals that are legislative fixes include the 2018 Holding bill and the 2024 LaHood bill. Significantly, neither bill ends citizenship as a sufficient condition for U.S. tax residency.

Regulatory Fix (mitigating the problems of citizenship taxation by regulation):

In 2020, Dr. Laura Snyder, Dr. Karen Alpert and John Richardson published “A Simple Regulatory Fix For Citizenship Taxation”. In this paper we demonstrated how Treasury through its regulatory authority could change the impact of the U.S. (domestic) Internal Revenue Code on on Americans abroad.

A Tax Treaty Fix To Citizenship Taxation:

In 2025, Dr. Laura Snyder, Dr. Karen Alpert and John Richardson published “A Simple and Unilateral Treaty Fix for Citizenship Taxation”. Both the paper and discussion is available at the SEAT site. Notably, this approach changes neither U.S. domestic law nor regulations. Rather, it simply argues that U.S. Treasury could refrain from exercising its rights under the “saving clause” found in U.S. tax treaties. The “saving clause” gives the United States the right (but not the obligation) to impose U.S. taxation on U.S. citizens abroad as though the treaty did not exist. Notably, this prevents U.S. citizens from using “tax treaty residency tie break” provisions to elect to be treated as tax residents of ONLY their country of residence. Incredibly, Green Card holders ARE permitted to (effectively) “opt in” to residence-based taxation.

The SEAT argument is that:

The United States could end the double taxation of Americans abroad simply by electing to NOT exercise its rights under the “saving clause”. This would allow President Trump to fulfill his pledge to end the “double taxation” of Americans abroad by NOT invoking the “saving clause”.

The argument is explained here:

A Simple and Unilateral Treaty Fix for Citizenship Taxation

Join us for discussion on October 8, 2025 – Two opportunities

1. Wednesday October 8, 2025 Youtube – 7:30 am Eastern (Toronto and New York) time

2. Wednesday October 8, 2025 – X. Spaces – 10:00 am Eastern (Toronto and New York) time

Slides for both presentations …

This is important! Hope you can make one or both of the discussions.

John Richardson – Follow me on X.com/@ExpatriationLaw

Shedding Light On The U.S. Citizenship Tax System And Prospects For Reform In Australia And More: Latife Hayson and Seth Hertz

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Reproduced from SEATNow.org

Introduction and purpose

In the summer of 2025 Latife Hayson of The Interchange, an Australian living in the United STates included an episode about U.S. citizenship taxation. Although mainly from an Australian perspective, the video (and shorts) will be of interest to U.S. citizens living all over the world.

Full Video:

US Expat Tax Explained: Navigating Citizen-Based Tax Traps & the Push for Residency-Based Taxation

Shorts:

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FATCA Is Not the Answer

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Reposted from SEATNow.org.

On February 26, 2024, Tax Notes Federal published an article entitled “Taxing Fat Cats Abroad.”

The article defended the Foreign Account Tax Compliance Act (FATCA) as an “automatic exchange of information used to track down and tax accounts held by wealthy U.S. citizens living abroad.”

The article contained many errors and misinterpretations.

SEAT co-founders John Richardson, Karen Alpert, and Laura Snyder submitted a response to the article, entitled “FATCA Is Not the Answer.”

Their response, published on March 18, 2024, can be accessed via SSRN at this link.

The response explains:

1. The considerable differences between FATCA and CRS. They include FATCA’s lack of reciprocity and the United States’ refusal to join CRS;

2. The inequalities inherent in the U.S. tax system with respect to Americans living outside the United States and their discriminatory treatment;

3. The irrelevance of FATCA with respect to Farhy v. Commissioner and Bittner v. United States;

4. The unjust stigmatization of Farhy, Bittner, and all Americans living outside the United States;

5. Inconsistencies between the article’s defense of citizenship-based taxation and the “single tax principle” advocated by professor Reuven Avi-Yonah;

6. The failure of the article, in its theorectical defense of citizenship-based taxation, to contend with the real system in place today and its myriad intractable problems;

7. The lack of any connection between taxation and voting rights;

8. The importance of the 14th Amendment for the equal protection of the rights of Americans living outside the United States; and

9. That the 16th Amendment is not — and it should not be used as — a license to channel violations of constitutional and human rights through the tax code.

John Richardson – Follow me on X.com

A simple regulatory fix for the problem of US citizenship taxation

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Background

In 2016 I first made the suggestion that citizenship-based taxation could be changed through Treasury regulation. In October of 2020 John Richardson, Dr. Karen Alpert and Dr. Laura Snyder completed a paper titled “A Simple Regulatory Fix For Citizenship Taxation”. The idea advanced is that:

Although Congress and the Internal Revenue Code created the problem of “citizenship-based taxation”, Treasury has the authority and moral duty to fix the problems of citizenship-based taxation.

Discussion

In 1924 the Supreme Court of the United States considered U.S. citizenship-based taxation in the case of Cook v. Tait. Of course in 1924, the laws of both citizenship and taxation were very different. I have previously explored the evolution of citizenship, taxation and citizenship-based taxation.

The article has received fairly wide distribution (including in the academic community).

Abstract

This article explains the simple regulatory actions that United States Department of the Treasury can take that would, in the absence of legislative change, improve the lives of Americans living overseas and permit the IRS to better focus its limited resources to more effectively administer the U.S. tax system.

The article can be read at SSRN here.

The 2020 article can be at Tax Notes here.

I welcome your comments.

John Richardson – Follow me on Twitter @Expatriationlaw

FATCA @Citizenshiptax and Wealth taxes: Laura Snyder Engages @Gabriel_Zucman In The Twittersphere

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Introduction

Citizenship-based taxation, FATCA and how the interact can best be understood by Americans abroad.

The professors (who have clearly never lived under a citizenship taxation regime and have limited understanding of FATCA) explain the relationship between U.S. citizenship-based taxation and the success of a – “Made In The USA” wealth tax – in the article which includes:

The situation in the United States is different. You can’t shirk your tax responsibilities by moving, because U.S. citizens are responsible to the Internal Revenue Service no matter where they live. The only way to escape the IRS is to renounce citizenship, an extreme move that in both Warren’s and Sanders’s plans would trigger a large exit tax of 40 percent on net worth.

Some people tweet. Some people tweet for fun. Some people tweet to educate.

The purpose this post is to collect the series of tweets that Laura Snyder complied to provide a higher level of education to the professors.

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Recently Released Survey Report Dispels Myth of the Wealthy American Abroad and Demonstrates Why Middle Class Americans Abroad Are Forced To Renounce US Citizenship

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This blog post features the research of Laura Snyder. It is (I believe) the single and most comprehensive study of (1) the U.S. legislation that is understood to apply to Americans abroad and (2) the disastrous impact this legislation has on them. To put it simply, Congress is forcing Americans Abroad to renounce their U.S. citizenship.

The bottom line is that for Amerians Abroad:

“All Roads Lead To Renunciation!”

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And now over to Laura Snyder with thanks.
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Part 15 in series: The Emotional Toll of US Non-Resident Taxation and Banking Policies – “I Just Wanted to Punch, Kick, Scream”

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Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows:

You are invited to submit your questions in advance. In fact, PLEASE submit questions. This is an opportunity to engage with Homelanders in general and the U.S. tax compliance community in particular.

Thanks to Professor Zelinsky for his willingness to engage in this discussion. Thanks to Kat Jennings of Tax Connections for hosting this discussion. Thanks to Professor William Byrnes for his willingness to moderate this discussion.

Tax Connections has published a large number of posts that I have written over the years (yes, hard to believe it has been years). As you may know I oppose FATCA, U.S. citizenship-based taxation and the use of FATCA to impose U.S. taxation on tax residents of other countries.
Tax Connections has also published a number of posts written by Professor Zelinsky (who apparently takes a contrary view).

You will find Part 1 to Part 14 of this series of posts here.

Laura Snyder discusses the “emotional toll of U.S. non-resident taxation and banking policies

Laura Snyder has written (in addition to her original four posts) a series of five posts describing and exploring “The Emotional Toll of US Non-Resident Taxation and Banking Policies“. Part 10 of this series (comments of Nando Breiter) was a prologue to Ms. Snyder’s five posts.

Now over to Laura …

Continue reading →

Part 14 in series: The Emotional Toll of US Non-Resident Taxation and Banking Policies – “Maybe that’s the Only Way Out”

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Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows:


You are invited to submit your questions in advance. In fact, PLEASE submit questions. This is an opportunity to engage with Homelanders in general and the U.S. tax compliance community in particular.
Thanks to Professor Zelinsky for his willingness to engage in this discussion. Thanks to Kat Jennings of Tax Connections for hosting this discussion. Thanks to Professor William Byrnes for his willingness to moderate this discussion.
Tax Connections has published a large number of posts that I have written over the years (yes, hard to believe it has been years). As you may know I oppose FATCA, U.S. citizenship-based taxation and the use of FATCA to impose U.S. taxation on tax residents of other countries.
Tax Connections has also published a number of posts written by Professor Zelinsky (who apparently takes a contrary view).
You will find Part 1 to Part 11 of this series of posts here.
Laura Snyder discusses the “emotional toll of U.S. non-resident taxation and banking policies
Laura Snyder has written (in addition to her original four posts) a series of five posts describing and exploring “The Emotional Toll of US Non-Resident Taxation and Banking Policies“. Part 10 of this series (comments of Nando Breiter) was a prologue to Ms. Snyder’s five posts.
Now over to Laura …
Continue reading →

Part 13 in series: The Emotional Toll of US Non-Resident Taxation and Banking Policies – “I Made a Poisoned Gift to My Daughter”

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Before moving to the post, if you believe that Americans abroad are being treated unjustly by the United States Government: Join me on May 17, 2019 for a discussion of U.S. “citizenship-based taxation” as follows:

You are invited to submit your questions in advance. In fact, PLEASE submit questions. This is an opportunity to engage with Homelanders in general and the U.S. tax compliance community in particular.

Thanks to Professor Zelinsky for his willingness to engage in this discussion. Thanks to Kat Jennings of Tax Connections for hosting this discussion. Thanks to Professor William Byrnes for his willingness to moderate this discussion.

Tax Connections has published a large number of posts that I have written over the years (yes, hard to believe it has been years). As you may know I oppose FATCA, U.S. citizenship-based taxation and the use of FATCA to impose U.S. taxation on tax residents of other countries.
Tax Connections has also published a number of posts written by Professor Zelinsky (who apparently takes a contrary view).

You will find Part 1 to Part 12 of this series of posts here.

Laura Snyder discusses the “emotional toll of U.S. non-resident taxation and banking policies

Laura Snyder has written (in addition to her original four posts) a series of five posts describing and exploring “The Emotional Toll of US Non-Resident Taxation and Banking Policies“. Part 10 of this series (comments of Nando Breiter) was a prologue to Ms. Snyder’s five posts.

Now over to Laura …

Continue reading →