Part 2: Cook v. Tait 19124: Evolution of U.S. citizenship http://t.co/xQpeowhPg3 Does citizenship taxation make sense in a #FATCA world?
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) May 12, 2015
Part 1 of this post traced the evolution of taxation.
This brings us to:
Part 2 – The Evolution of Citizenship
In 1924, the Supreme Court of the United States, per Justice McKenna ruled in Cook v. Tait that U.S. “citizenship taxation” was constitutional. Since that time Cook v. Tait has been cited to justify the constitutionality, although not necessarily the propriety, of “citizenship taxation”. Note that “citizenship taxation” contains both the words “citizenship” and “taxation”. As a result, Justice McKenna’s decision along with the relevant statutes, may tell us a great deal about what “taxation” and “citizenship” meant in 1924.