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2012 July 9 – Mopsick

Steven J. Mopsick
Tax justice for Americans abroad
Tax Notes (9 July 2012) 189-196


A federal tax attorney with long experience within the IRS details the problems currently faced by U.S. persons living outside the United States. He usefully categorizes the options — “few good”! — available to “those with reasonable cause arguments” and reduces them from an apparent six to three that he sees as “realistically viable.” He illustrates difficulties with a substantial hypothetical case study of an extended family that has generations of history in Vancouver, British Columbia. “Responsible people in the government must see the absurdity of how citizenship-based taxation affects expatriates and the bizarre fact that the United States is the only country that taxes its citizens on their worldwide income.” Mopsick proposes a “facts and circumstances test” as a potentially useful “commensense approach” (p. 193), but irrationally persists in privileging the fact of birth abroad in designating persons who have had “no meaningful economic connection to the United States” over a period of many years. [14 footnotes]

Written by usxcanada

9 July 2012 at 6:00 am