My (John Richardson) interpretation of the current situation:
1. The problems experienced by US citizens living outside the United States can be solved ONLY by severing US citizenship from US tax residency. In other words: citizenship cannot be the criterion for being subject to the Internal Revenue Code. No other country in the world (except Eritrea) imposes worldwide taxation based on and only citizenship. All other countries in the world have residence based taxation which means that residence and not citizenship is the criterion for tax residency.
Complete relief for Americans abroad can be achieved ONLY by severing citizenship from the definition of US tax residency.
2. There is a difference between a “wish” and a “goal”:
“The dictionary defines a wish as: to want; desire; to long for. Goals on the other hand are defined as: the result or achievement toward which effort is directed. The difference is profound not only in semantics, but also in how each can shape your thought process, your actions (or lack of), and ultimately, your life.”
3. Individual Americans abroad have a “wish” for residence based taxation. That said, “residence based taxation” is NOT their goal. Their goal (if any) is to solve “their” problem (how they experience citizenship taxation) and not “the” problem “citizenship taxation itself. For example, solving the FATCA problem will NOT solve the problem of citizenship taxation.
4. No organizations except SEAT and Republicans Overseas have the specific goal of severing citizenship from tax residency.
5. Without pressure (which simply doesn’t exist) from large numbers of individual Americans abroad there is no political impetus for any legislative change to residence taxation.
To be clear, there will be a lawsuit challenging the current application of the rules to citizenship taxation to Americans abroad. It may take more time than the current generation of Americans abroad has.
In summary, there is little support for the “goal” of severing citizenship from tax residency.
In addition …
The situation for Americans abroad is NOT getting better and has in fact gotten worse over the last ten years. I will continue to work with “like minded” people and “organizations” to achieve the goal of severing citizenship from tax residency. That said, this will take more time than this generation of Americans abroad has!
What all of this means is that …
“All Roads Lead To Renunciation” (as soon as that goal is possible).
John Richardson – Follow me on Twitter @Expatriationlaw