Prologue – The need to end Double Taxation and President Trump’s pledge
If you just want to sign the petition to help- Please by October 30/26
We invite you to join us in signing the RO Petition letter (see the text of the letter below) to the U.S. Treasury and IRS for the purpose of ending double taxation by clicking this link:
https://speak4.app/lp/4d01inqk
(You may need to use a U.S. address and zip code.)
The background and explanation for the request
The podcast with Solomon Yue
The explanation for the “Simple Regulatory Fix To End Citizenship Taxation”
A Direct Link To The Tax Notes article
John Richardson – Follow me on X.com/Expatriationlaw
Appendix – The Letter From Solomon Yue
The “call to action” for Amerians abroad is as follows:
Republicans Overseas is petitioning the Treasury and IRS to endors residence-based-taxation and propose legislative language to Congress:
We invite you to join us in signing the RO Petition letter (see the text of the letter below) to the U.S. Treasury and IRS for the purpose of ending double taxation by clicking this link: https://speak4.app/lp/4d01inqk
Republican Overseas Pettition Letter to Secretary Bessent:
To the U.S. Department of the Treasury, Office of Tax Policy:
I am an American citizen living and working overseas, and I write in support of the effort led by Republicans Overseas Action to end the double taxation of Americans abroad.
For some background, Title 26 of the Code of Federal Regulations, § 1.1-1(b), provides that all American citizens, regardless of where they live and work, are subject to federal income tax. For me and millions of others, that obligation comes in addition to the tax levied on our income by the nation in which we live.
The United States is an international outlier among advanced economies. It is one of only two nations in the world that taxes its citizens on the basis of citizenship rather than residence; the other is the State of Eritrea.
Ending double taxation has been publicly supported by President Trump. In a video released in October 2024, he said: “I’m going to end double taxation on our overseas citizens. You’ve been wanting this for years, and nobody has listened to you, and you deserve it, and I’m going to do it. It’s the right thing to do . . .”
I recognize that § 1.1-1(b) implements provisions of the Internal Revenue Code that impose tax on the worldwide income of United States citizens, and that residence-based taxation may therefore require congressional action. However, the Department of the Treasury possesses substantial authority under 26 U.S.C. § 7805(a) to clarify and administer the Code and to reduce unnecessary compliance burdens, and the Department is positioned to recommend amendments to the internal revenue laws.
I therefore petition the Department, pursuant to 5 U.S.C. § 553(e), to initiate a rulemaking that extends to qualified nonresident citizens the relief existing law permits, including simplified filing, expanded safe harbors, penalty relief, and improved coordination of the foreign earned income exclusion and the foreign tax credit, providing a pathway to end double taxation. To the extent the Department concludes that complete implementation requires legislation, I request that it transmit proposed statutory language to Congress and formally endorse its enactment.
In addition, I respectfully request that the Department of the Treasury:
publicly endorse residence-based taxation for qualified nonresident United States citizens;
develop and transmit to Congress proposed statutory language implementing that policy;
identify other administrative and regulatory reforms it can lawfully adopt under existing statutes to reduce duplicative filing and compliance burdens; and
undertake notice-and-comment rulemaking promptly following enactment of the necessary legislation.
Americans who live and work overseas promote American values, American culture, and American business practices, increase American influence, and open new markets for American businesses. Excessive tax and reporting burdens discourage Americans from accepting foreign assignments, and they make posting U.S. citizens abroad far more costly than it is for foreign competitors to post their own nationals. The result has been a recent surge in Americans living abroad renouncing their citizenship.
When these barriers prevent Americans from accepting foreign assignments, those positions may be filled by foreign workers instead. That can weaken America’s standing in the global business community, reduce American influence over international commercial decisions, and create potential national security vulnerabilities. American companies prefer American personnel in these roles because of their familiarity with U.S. business practices, legal obligations, security standards, and institutional priorities.
This policy change is in line with the President’s objectives, would in my view carry minimal financial impact to the U.S. Government, and would meaningfully support Americans who are currently subject to double taxation. I respectfully request that the Department provide a written response identifying: (1) the reforms it believes it can undertake under existing authority; (2) the statutory amendments necessary to establish residence-based taxation; and (3) whether it will include such amendments in the Administration’s next revenue proposals.
Thank you for your time and consideration on this very important matter.
Sincerely,
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Any U.S. citizen over the age of 18, living outside the United States is eligible to sign this letter. In order to expedite our request to the Treasury Secretary, we ask that you sign this by the end of October
Thank you.
Solomon Yue
Vice Chairman and CEO
Republicans Overseas, Inc. and Republicans Overseas Action, Inc.
Retired 8th in seniority among the 168 RNC members after 24 years