SEAT Working Papers Series - Extraterritorial Taxation #1: How It Has Evolved

PREP Podcaster - ”Success Favours The PREPared Mind”

November 22, 2023 - Participants include:

Dr. Karen Alpert - @FixTheTaxTreaty

Dr. Laura Snyder - @TAPInternation

John Richardson - @Expatriationlaw

The purpose of SEAT has been and continues to be to conduct research (including the SEAT survey), prepare position papers, make submissions by SEAT to various governments, facilitate advocacy by individuals impacted, file amicus briefs and provide a centre for educating interested parties about the U.S. extra-territorial tax regime. (SEAT's work may be found on the SEAT website.)

SEAT believes that the problems caused to Americans abroad by the U.S. extraterritorial tax regime can be ended ONLY by severing citizenship from tax residency. We encourage the United States to join the rest of the world by taxing individuals on the basis of residence and source and NOT based on the citizenship of an individual.

Part of SEAT's work has been break our research into specific issues and categories. These categories are expressed as "SEAT Working Papers". In order to make the "SEAT Working Papers" available in podcast form, SEAT co-founders Karen Alpert, Laura Snyder and John Richardson are developing a series of podcasts - featuring interactive discussion - where we distill the "working paper" into conversational format. It is our hope that these podcasts will make SEAT's content available to a larger group of people.

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This is the first in a series of podcasts to that are paired with various working papers and articles created by members of SEATNow.org

SEAT Working Paper Series #2023/1 Extraterritorial Taxation #1: How It Has Evolved

Since Cook v. Tait was decided in 1924 much has changed, with respect to both federal taxation and U.S. citizenship. This paper explains their parallel evolutions and why they call for Cook to be revisited.

Available at: https://ssrn.com/abstract=4464210