Changing U.S. Tax Jurisdiction: Expatriates, Immigrants, and the Need for a Coherent Tax Policy

92 Pages Posted: 15 May 2016

Date Written: March 1, 1997

Abstract

Over the last eighty years, Congress has failed to develop a coherent approach to persons and property changing U.S. tax jurisdiction. Congress has enacted a comprehensive regime to address the transfer of property outside the U.S. when the beneficial owner of the property continues to be subject to U.S. residence basis taxation. This regime, however, is inconsistent with that applicable to property leaving and entering U.S. tax jurisdiction because the owner of the property leaves (expatriates) or enters U.S. tax jurisdiction, even though identical tax policy issues arise. This article argues that Congress should adopt a mark-to-market tax regimes for persons and property that enter or leave U.S. residence or trade or business taxation.

Suggested Citation

Colon, Jeffrey Miguel, Changing U.S. Tax Jurisdiction: Expatriates, Immigrants, and the Need for a Coherent Tax Policy (March 1, 1997). San Diego Law Review, Vol. 34, No. 1, 1997, Available at SSRN: https://ssrn.com/abstract=2779139

Jeffrey Miguel Colon (Contact Author)

Fordham University School of Law ( email )

150 West 62nd Street
New York, NY 10023
United States

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