Jackie Bugnion (American Citizens Abroad), Recommendation for U.S. International Tax Law Reform, 66 Tax Notes Int'l 459 (Apr. 30, 2012):
For reasons detailed below, ACA proposes two complementary changes to U.S. tax laws as they apply to American citizens and green card holders resident abroad:
- Eliminate citizenship-based taxation.
- Collect withholding taxes at source on all U.S. passive income (including dividends, interest, royalties, etc.) of overseas Americans on the same basis as the U.S. currently collects withholding taxes on the revenues generated by U.S. assets, such as shares and bonds, owned by non-resident foreigners.
The ACA proposal would make the United States more competitive in world markets, create jobs at home, simplify taxation for Americans living abroad, alleviate the burden on the IRS, and be revenue neutral (possibly even positive) for the United States.
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