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:
A collection of topical videos from @RepOverseasTax and @Expatriationlaw explaining the problems caused by @citizenshiptax and why the only solution is separating citizenship and @TaxResidency. This problem is urgent and must be dealt with now. https://t.co/yDEysnoQUc
— John Richardson – Counsellor for US persons abroad (@ExpatriationLaw) September 18, 2024
John Richardson – Follow me on X.com @ExpatriationLaw