As far as I know no comprehensive effort has ever been undertaken to determine the total revenue impact of CBT, including revenue lost to the tremendous disincentives and opportunity costs it imposes upon American businessmen. The argument put forth for CBT is that all Americans should be taxed the same, yet the multiple instances of double taxation of Americans abroad demonstrate exactly the opposite. The fundamental justification for taxation is that it funds taxpayer services. CBT contradicts this principle, as the pension, healthcare, education, and infrastructure costs that overseas Americans engender are paid for by foreign governments and the taxpayers themselves. Conversely, the imposition of a "sui generis" extraterritorial tax regime manifests a decision on the part of the US to unilaterally grant itself the right to extract from the economy of every other country a scarce and strategic economic source : cash.
Even tough the US recognizes the first right of taxation to be with the country of residence, CBT systematically penalizes Americans abroad. It does not take into consideration the total tax burden imposed on individuals by their country of residence (SS, net wealth and indirect taxes like VAT, excise taxes etc...) . Would it be such a stupid idea if we change the current CBT (citizenship based taxation) into a fee based system for the approx. 7 million expats who live and work outside the US.
How about an annual fee of $100 per USP and only the duty to file a NRA tax return if and when US sourced income exists. This would be a win-win situation for everybody. This would save the IRS and Treasury 90% of their current compliance budget with regards to FEIE and FTC audits and tax return processings BUT it would generate imediatedly a revenue stream of $700,000,000 annually (7mio X $100) with little cost associated .
On the other side the approx. 7 mio expats would not have to spend $1,2 or 3,000 annually on tax preparation fees and would not need a CPA or tax lawyer anymore and more importantly could use and benefit from the tax system (retirement planing) of their current country of residence.
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