Citizenship & Taxation Symposium - October 9, 2015

Citizenship and Taxation Symposium, University of Michigan Law School, Ann Arbor, Michigan - Friday, October 9, 2015.

This symposium focused on ongoing developments regarding the unique US practice of taxing citizens who live permanently overseas. With the adoption of regimes such as the expatriation tax added by IRC § 877A and the Foreign Account Tax Compliance Act (FATCA), the taxation of non-residents with US person status now has serious and tangible implications. 


Like most countries, the United States claims the right to tax on a worldwide basis all of the people resident in its territory regardless of their legal status. But virtually alone in the world, the United States also claims worldwide fiscal jurisdiction over its citizens whether or not those persons are or ever have been resident within the territory. The legal claim over citizens dates to the first national income tax and has been continued through the present, but enforcement has always been an abstract ideal rather than a viable program.

This status quo has dramatically changed as an unexpected side effect of the adoption of the Foreign Account Tax Compliance Act (FATCA) in 2010. By introducing an unprecedented regime for global third party reporting, FATCA enables the IRS to enforce citizenship taxation on a worldwide basis for the first time in the history of the income tax. As will becomes ability, the normative foundations of citizenship taxation are coming under intense scrutiny.

To explore these issues, the symposium presenters offered different perspectives on the meaning, feasibility, efficiency, and fairness of the U.S. practice of citizenship taxation, and commented on the practical and policy effects of new legislative developments. We invited proposals that consider U.S. citizenship-based taxation from a historical, economic, social, political, institutional, or philosophical perspective. 

Symposium Participants

In addition to the conveners, the symposium featured a panel of distinguished speakers, including:

  • Wei Cui, University of British Columbia School of Law
  • Tessa Davis, University of South Carolina Law School
  • Michael Kirsch, Notre Dame Law School
  • Patrick Martin, Procopio, Cory, Hargreaves & Savitch LLP
  • Ruth Mason, University of Virginia Law School
  • Saul Templeton, University of Calgary Faculty of Law
  • Phil West, Steptoe & Johnson
  • Ed Zelinsky, Cardozo School of Law

The Symposium was jointly hosted by the University of Michigan School of Law, the McGill University Faculty of Law, and Procopio, Cory, Hargreaves & Savitch LLP

Guide for Proposals

  • Deadline for proposals: February 28, 2015. Now closed.
  • Paper proposals must be between 300–500 words in length and should be accompanied by a CV.
  • Successful applicants will be notified by the end of March 2015.
  • Proposals should be submitted by email to Reuven Avi-Yonah (aviyonah [at] and to Allison Christians (allison.christians [at]
  • Successful applicants must submit a working draft of their paper by September 8, 2015 for circulation among conference participants.
  • Some support will be available for travel and accommodations; please indicate in your proposal should you require it.
  • We anticipate gathering papers for a potential symposium issue or edited volume.