Debunking Harvard Law Review's Misrepresentations on Americans Abroad And The U.S. Exit Tax

PREP Podcaster - ”Success Favours The PREPared Mind”

SEAT has prepared a new survey and is asking both current and former Americans abroad to participate. Advocacy for Americans abroad is greatly enhanced by the availability of current information. The survey is on the SEAT site:

https://seatnow.org/2024/06/14/tell-your-story/

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June 25, 2025 - Participants include:

Dr. Karen Alpert - @FixTheTaxTreaty

Anthony Parent - @IRS_Medic

Keith Redmond - @Keith__Redmond

Dr. Laura Snyder - @TAPInternation

John Richardson - @Expatriationlaw

A recent post by Paul Caron: https://taxprof.typepad.com/taxprof_blog/2024/06/harvard-law-review-moore-section-877a.html The Note published in the Harvard Law Review disparaging Americans abroad: https://harvardlawreview.org/print/vol-137/moore-than-meets-the-i-r-c-the-apportionment-rules-originalist-backstop-for-i-r-c-%c2%a7-877a/ SEAT's response to the Note : http://seatnow.org/2024/06/22/harvard-law-reviews-drive-by-attack-on-overseas-americans/ Harvard Law Review declined to publish Snyder's response to the Note. This podcast discusses both the Note and Harvard Law Review's failure to publish any correction of the Note.

AI Description:

"Join John Richardson and a panel of experts as they dissect the recent Harvard Law Review note that attempts to defend the constitutionality of the U.S. Exit Tax. The episode features Anthony Parent from the IRS Medic podcast, along with SEAT members and co-founders Keith Redmond, Karen Alpert, and Laura Snyder.

The discussion kicks off with an overview of the Exit Tax, a levy imposed on Americans renouncing their citizenship to escape U.S. taxation. The panel critiques the Harvard note for its factual inaccuracies and defamatory statements about Americans living abroad. They argue that the article misrepresents the reasons behind renunciations and fails to consider the complex compliance issues faced by expatriates.

Further, the conversation explores the broader implications of the Harvard Law Review's stance, the need for severing citizenship from tax residency, and the potential unconstitutionality of the Exit Tax post-Moore decision. The panel also highlights the importance of advocating for the complete severance of citizenship from tax residency to solve the problems faced by Americans abroad.

Tune in for an insightful debate on the flaws in the Harvard Law Review note and the broader issues of U.S. taxation on expatriates."