Document Type

Article

Publication Date

2025

Abstract

President Trump proposed during the election campaign to end the “doubletaxation” of American citizens living overseas.To which the answer is,what double taxation?Americans living overseas already benefit from three significant provisions thatin most cases prevent any double taxation, and because of these most of them donot have any U.S. tax liability.Those who do are typically wealthier, derive incomefrom investments or from high wages, and are not subject to foreign tax becausethey live in tax havens or in countries that do not tax rich immigrants on foreignsource income, and they do not have any income from their country of residence.

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© 2025 R. S. Avi-Yonah. This article is reprinted with the publisher’s permission from International Tax Journal, a bimonthly journal published by CCH Incorporated. Copying or distribution without the publisher’s permission is prohibited.

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