Still, I’m hard pressed to harbor too much ill-will toward those who leave the U.S. for precisely the same reason so many others want to enter it. The solution is not to punish those who want more freedom, but to fix our laws so that those who seek maximal freedom will want to come here.

and you got me, sortof, the $82,400 is a deduction… but there is a foreign tax credit Form 1116 where you get to offset your US taxes dollar for dollar for taxes paid overseas (just like most states give residents a tax credit for taxes they’ve paid on income earned/taxed in other states)… so there isn’t any double tax.

so the only people who are screaming about having to pay the IRS are the ones who packed up and left for a country with tax rates lower than ours. forgive me for not mentioning them in my prayers tonight.

I’m not going to get bent out of shape over a tax that applies to very few people, all of whom are spitting in the face of Americans with their opting to pursue citizenship elsewhere.

Setting aside the silliness of equating foreign citizenship with spitting in the face of Americans (are all naturalized American citizens “spitting in the faces” of their former countrymen, too?), the Asshole Tax is not a special tax on Americans who renounce their citizenship. It is imposed on all Americans who earn money abroad, whether they retain their U.S. citizenship or not. In fact, “spitting in the faces” of their fellow Americans is the only way they can escape that tax – eventually.

And it’s a quibble, but the $82,400 limit is a tax credit[.]

No, it’s not, even if I did lazily employ that word myself in a prior comment. As Form 2555-EZ makes clear, $82,400 is the maximum amount of excludable income, not a dollar-for-dollar credit against taxes paid to other jurisdictions.

So I can guess how much you like the states taxing their residents on all their income, regardless of whether it was earned out of state…

While I usually don’t frown on those who use the tax code to their advantage, a lot of the people caught in this were simply looking to shelter future income by moving out of the country, not because they’re truly renouncing their citizenship. that’s why the ten year period applies, to keep people from, for example, moving abroad and then immediately liquidating their portfolio or selling their business.

And I don’t like this tax, I was merely offering up a defense of it. Nor do I hate rich people (I hope my kids are rich some day). Having said that, as there are unfortunately many bigger injustices in the wonderful world of tax law (such as the rule that substance takes precedence over form), I’m not going to get bent out of shape over a tax that applies to very few people, all of whom are spitting in the face of Americans with their opting to pursue citizenship elsewhere.

And it’s a quibble, but the $82,400 limit is a tax credit, so the poor lady can shelter close to a quarter of a million dollars in ordinary income, over a half of a million in dividends and capital gains. Per Adam Sandler, not too shabby.

So it sounds like you think that I’m on the right track with my general theory of libertarianism. That it does not tolerate “the greatest good for the greatest number” with a necessary corollary of “acceptable losses”. Or would you say that such thinking is not restricted to libertarianism but is, or should be, also part of conservatism?

I think the general tone of your comment, along with Steve’s, sums up the theory behind the Asshole Tax more succintly any substantive argument can: populist ‘Mercuns don’t much like rich people, and they really don’t like expatriates, so right or wrong, fair or unfair, let’s sock it to the rich expatriates. So go ahead, feel good about that asinine policy if you must, just don’t criticize the liberals for feeling equally good about the equally misguided and equally unfair (and, at least in some cases, *more* popular) policies that they support.

I will never forget being in Monte Carlo on the 4th of July looking out over all the American tax avoiders in their yachts watching the fireworks for Independence Day. I am almost always for lower taxes but have very little sympathy for people who “love our milk and honey” but go on about “some other way of living.” As the song says, “if you don’t love it, leave it.” Just renounce your citizenship and have some other country defend you.

NK: What social[-ist] “contract?” I never signed one, and if the body of law as we know it were presented to you to accept or reject in the form of a contract, I doubt you would, either. I’m not complaining – laws aren’t supposed to be contractual – I just have little patience for the contrived theory that by existing I should be deemed to have “agreed” to terms I was never given a reasonable opportunity to accept or reject – and which would likely be struck down as unconscionable if I had.

I am starting to see the big picture about libertarian philosophy vs. liberal or conservative. Liberals and conservative have a “collective bargaining agreement” view of the Social Contract whereas libertarians want individually negotiated agreements. Or not?

and since when have you started judging the appropriateness of a government policy on the basis of how many other countries do the same? does this mean we can count on your supporting gun controls and eliminating the death penalty?