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Full-Text Articles in Law
Taxing Citizens In A Global Economy, Michael S. Kirsch
Taxing Citizens In A Global Economy, Michael S. Kirsch
Journal Articles
This Article addresses a fundamental issue underlying the U.S. tax system in the international context: the use of citizenship as a jurisdictional basis for imposing income tax. As a general matter, the United States is the only economically developed country that taxes its citizens abroad on their foreign income.
Despite this broad general assertion of taxing jurisdiction, Congress allows citizens abroad to exclude a limited amount of their income earned from working outside the United States. Influential lobbying groups, including businesses that employ significant numbers of U.S. citizens abroad, argue that this exclusion is necessary in order to keep American …
Grasping Smoke: Enforcing The Ban On Political Activity By Charities, Lloyd Histoshi Mayer
Grasping Smoke: Enforcing The Ban On Political Activity By Charities, Lloyd Histoshi Mayer
Journal Articles
The rule that charities are not allowed to intervene in political campaigns has now been in place for over fifty years. Despite uncertainty about the exact reasons for Congress' enactment of it, skepticism by some about its validity for both constitutional and public policy reasons, and continued confusion about its exact parameters, this rule has survived virtually unchanged for all of those years. Yet while overall noncompliance with the income tax laws has drawn significant scholarly attention, few scholars have focused on violations of this prohibition and the IRS' attempts to enforce it.
This Article focuses on the elusive issue …