When the US Congress considers legislation, one of the standard criteria often applied is that the proposed bill should be revenue neutral – that is, any new costs must be offset by new revenue. But, should this be a consideration for proposals to move to a system of residence based taxation?
No other developed country taxes nonresidents solely on the basis of citizenship. Those who left the US as toddlers to return to their parents’ home country are (under US law) US citizens, but most do not identify as Americans and have few, if any, ties to the US. Taxing the residents of other countries who no longer have substantial ties with the United States is clearly over-reach. While there might be many opinions about exactly where to draw the line, a line must be drawn. It is a question of doing the right thing – and the revenue generated does not alter the immorality of taxing those who are clearly domiciled in other countries.
Furthermore, it is not clear how much revenue is actually generated by the taxation of nonresident citizens – or how much revenue might be generated by taxing nonresidents under the provisions currently applied to nonresident aliens. So any calculation of “revenue neutrality” is only a very rough approximation.