Citizenship based taxation came about because of war, the Civil War to be exact and was meant as a punishment for those leaving the U.S. and not supporting the war. I think it's time and purpose has come and gone.
It's long past time that the U.S. does go to RBT at least for long term expats. I think it's rather backward to continue with CBT when no other nations besides the U.S. and Eritrea do such as this. Should those citizens not living in the U.S. continue being punished for not doing so? Because that's what it is. 82 percent of all expats never end up owing the U.S. taxes on earned income abroad. The vast majority are not rich enough for that. It does however mean you spend a lot of money showing you don't owe and for some low income families that's a burden that they can no longer bear.
I think it's high time there was an open and serious discussion as to why the U.S. thinks continuing CBT makes any sense at all given the fact it is not an international norm, does not raise enough revenue to off set the cost to implement it, and hampers efforts to catch real tax cheats living in the U.S.
The reason Dems Abroad did not fully implement the proposals from ACA to House Ways and Means was that they knew they could not offend the crafters of FATCA. That left the door wide open for the Republicans to take this issue away and try to get votes and funds off the issue. Should the Democrats adopt the proposal of semi RBT for long term expats only that would certainly shut down all or most opposition to FATCA.
I don't like to see this issue become a battle for election fodder. It's far more serious than that. I also hate false arguments "Opposition to Fatca = tax evasion cheer leader" That's not the reason for opposing it as it stands at all for most expats anyway.
The U.S. would be FAR more efficient in addressing tax havens within it's own borders such as Delaware which has more shell companies than the Cayman Islands in ONE building by going to RBT. It could also silence ALL opposition to FATCA and take this issue away from the Republicans.
As was proposed by ACA...go to RBT as an opt in for long term expat families outside the country longer than five years with NO U.S. earnings or holdings. Should you elect to opt into RBT and meet the requirements you would then have to agree to be taxed as a foreign citizen on any future U.S. inheritance or holdings or earnings. So should your U.S. parent die you will have to pay 30 percent, the same as a foreigner. This would generate more taxes than the way things are currently done, take away the vast majority of the issues with FATCA and not allow Republicans to co opt this issue. No it's not full RBT but, it avoids long term expats and their families being subjected to all the pit falls of CBT causing so many hardships and objections to FATCA.
Instead Democrats Abroad were rather restricted in what they could propose...that's too bad since there are reasonable workable solutions that still go after tax cheats while not harming long term expats and our foreign families.
This is going to get ugly here in Canada. Progs here are fighting it on quite a few fronts...the NDP, The Liberal Party, the Green Party and the Canadian Civil Liberties Association all raising opposition to Canada implementing this.
That's why I think there ought to be an open and serious discussion by the Democrats on RBT vs. CBT. It is NOT unreasonable for Democrats to consider the proposition made by ACA to House Ways and Means committee.