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Tax Considerations For The Potential U.S. Annexation Of Greenland

Libin Zhang (Fried Frank, New York), Tax Considerations for the Potential U.S. Annexation of Greenland, 186 Tax Notes Fed. 1843 (Mar. 10, 2025):

Tax-notes-federalThere have been many proposals over the last 150 years for the United States to acquire Greenland. However, the tax scholarship literature has neglected to focus on the tax consequences of such an annexation. Important and understudied issues include the taxation of the 58,000 Greenlanders, corporate taxation of controlled foreign corporations, and the potential extension of qualified opportunity zones to the world’s largest island. This article contributes to the growing field of critical tax manifest destiny studies as the United States reconsiders its territorial scope from the Arctic Ocean to the Gulf of America (Gulf of Mexico).

Every day, schoolchildren across America recite the names and capitals of some or all of the 50 states and five populated U.S. territories.  They might one day add Greenland and Nuuk to that list, and sing patriotic songs with some slight modifications provided by generative AI:

America the Beautiful feat. Greenland (2025 version)
O beautiful for spacious skies,
For amber waves of grain,
For frosty fjords where seals reside
And purple mountain reign!
America! America!
God shed His grace on thee,
From icy coasts to golden hosts,
And crown thy good with brotherhood
From sea to shining sea.
O Greenland’s vast and icy shores,
With glaciers pure and grand,
Your towering cliffs and tundra wide,
A wonder in our hand.
Greenland! Greenland!
God bless your frozen might,
With beauty bold and stories told
Beneath the northern light.
O beautiful for treasures deep,
Under both earth and ice,
For minerals rare and wealth to share,
A future to entice!
America! America!
May Greenland join the way,
And both shall stand, united lands,
In freedom's bright array.

The analytical discussion can also lead to future research by the tax law community about the tax consequences and transitional issues if Canada were to be admitted to the United States — either as the 51st state or the 51st through 60th states. 

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