Introduction – What is the Revenue Rule?
Q. Is it hard for countries to collect tax debts from residents of other counrries? A. I'ts the "Revenue Rule". In tax law, absent special enforcement treaties, sovereign countries do not enforce the revenue laws of other countries (the "revenue rule"). https://t.co/N4ZX4LJPSv pic.twitter.com/idRq77GvYv
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 1, 2019
The “Revenue Rule” can be overridden by statute of by treaty. The United States is attempting to override the “Revenue Rule” through changes to tax treaties. Because the United States imposes worldwide taxation on the residents of other countries, the United States would be advantaged overriding the “Revenue Rule”.
Putting the “Revenue Rule” in historical context. Does the Revenue Rule still matter?