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Section 911 Reform
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Leveling the Playing Field for Overseas Americans to Make the United States More Competitive
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The Issue:
The United States is among the tiny handful of nations that imposes
double-taxation on the labor income that individuals earn in other nations
- even if the U.S. citizen is a full-time resident of the foreign jurisdiction. Yet since the "foreign-source" income of U.S. citizens already is subject to all applicable taxes that exist in other jurisdictions, an additional layer of U.S. tax is double-taxation - thus violating one of the most important principles of good tax policy. Almost every other country in the world taxes only income earned inside national borders - the common-sense principle of "territorial taxation." American legislators have tried to mitigate the adverse impact of worldwide taxation by allowing workers to protect annual earnings up to $82,400 from double-taxation. This policy, known as the Section 911 exclusion, is a small step in the right direction. See this link for more information.
The Solution:
Ideally, the U.S. government should not be taxing
any income earned abroad - just as foreign governments should not be taxing any income earned in America. If policy makers created a level playing field by making Section 911 universal, more Americans could find jobs in the global economy, U.S. companies would become more internationally competitive, and U.S. exports would substantially increase.
The Legislation:
U.S. Senator Jim DeMint of South Carolina has introduced S. 1140, the Working American Competitiveness Act that will eliminate the cap on income Americans working abroad can earn without being double taxed. ... Section 911 of the U.S. tax code only allows Americans working abroad to protect $82,400 of their foreign earnings from U.S. taxes, but every other developed nation allows their workers to protect all of their foreign income. Our competitors understand that they are already taxed by the nations where their citizens live and work, and that their companies would have a harder time competing in the global economy if their citizens were taxed by two countries. The legislation would eliminate double-taxation on the foreign income of U.S. citizens. Other nations would continue to tax that income, just as the United States taxes the income of foreigners who live and work in America. [FYI: Text of DeMint's Press Release on the introduction of the same bill last Congress.
]
The Coalition for Tax Competition:
Reforming Section 911 and shifting the U.S. to a territorial
tax system are major goals of the Coalition for Tax Competition. The Coalition
is leading the educational and public relations effort to change the minds of policymakers and lawmakers in Washington. This web page will be updated when new information is available.
Please contact us at 202-285-0244 or section911@freedomandprosperity.org if you would like to get involved. We are also collecting contributions to help fund our project (see information below).
If you want to help:
Please send all contributions to CF&P Foundation's Section 911 Project,
P.O. Box 10882, Alexandria, Virginia 22310. Or contact us at 202-285-0255 (section911@freedomandprosperity.org) to receive wire transfer coordinates.
CF&P Foundation is a not for profit organization incorporated under Section 501(c)(3) of the Internal Revenue Code. Please note that donations to CF&P Foundation are tax deductible for U.S. individuals and companies.
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What's New
April 18, 2007 ~ Text of Senator Jim DeMint's Working American
Competitiveness Act, S. 1140
January 2007 ~ American Citizens Abroad, Stop killing the goose that lays the
golden egg Stop the double taxation on Americans working abroad
December 19, 2006 ~ Dan Mitchell Wrote: America's
awful worldwide tax system driving some Americans to give up citizenship
December 4, 2006 ~ Dan Mitchell Wrote: Section 911 provision having harsh
impact on U.S. competitiveness
October 19, 2006 ~ Sven Larson Wrote: Some
good news in the Section 911 battle
September 20, 2006 ~ Sven Larson Wrote: The high cost of double-taxing overseas Americans
Sept. 1, 2006 ~ International Herald Tribune, By Keith Bradsher, For U.S. workers abroad, tax bill proves a handicap
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Links
DeMint's Legislation
Columns and News Reports
CF&P Studies, Releases and Blog Entries
Letters of Support for DeMint Legislation
Other Links
American Citizens Abroad
Democrats Abroad
Republicans Abroad
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Columns and News Reports
January 2007 ~ American Citizens Abroad, Stop killing the goose that lays the golden egg
Stop the double taxation on Americans working abroad
http://www.aca.ch/goldgoos.pdf
December 18, 2006 ~ The New York Times, by Doreen Carvajal, Tax Leads Americans Abroad to Renounce U.S.
http://www.nytimes.com/2006/12/18/world/18expat.h
tml?_r=1&em&ex=1166504400&en=4a9&oref=slogin
December 1, 2006 ~ Tax-News.com, by Mary Swire, US Expats Look To Home As Tax Changes Bite
http://www.tax-news.com/asp/story/story_open.asp ?storyname=25628
October 11, 2006 ~ Wall Street Joural, Review & Outlook, Whew!
http://online.wsj.com/article/SB116053381670188973. html?mod=opinion&ojcontent=otep (subscription required)
September 1, 2006 ~ International Herald Tribune, By Keith Bradsher, For U.S. workers abroad, tax bill proves a handicap
http://www.iht.com/articles/2006/09/01/yourmoney/ money.php
July 19, 2006 ~ The Wall Street Journal, By Cris Prystay and Tom Herman, Tax Hike Hits Home For Americans Abroad: Higher Levy on Expatriates
Spurs Employers To Rethink Hiring Policies, Especially in Asia
http://online.wsj.com/article/SB115326457620010424.
html?mod=politics_secondary_stories_hs
July 10, 2006 ~ Bloomberg, by Ryan J. Donmoyer, Expatriate Americans, and Their Employers, Face a Tax Increase
http://www.bloomberg.com/apps/news?pid=2060110 3&refer=news&sid=ayRKGUvDf01w
June 28, 2006 ~ Washington Post, By Daniel J. Mitchell, Tax Me Once, Shame on You . . . Tax Me Twice and the System Needs Fixing.
http://www.washingtonpost.com/wp-dyn/content/ar ticle/2006/06/27/AR2006062701022.html
June 28, 2006 ~ The Wall Street Journal, By Newt Gingrich and Ken Kies, Our Taxed Expats
http://www.newt.org/backpage.asp?art=3145
May 30, 2006 ~ The New York Times, By Keith Bradsher and David Cay Johnston, Americans Living Abroad Get a Nasty Tax Surprise
http://www.nytimes.com/2006/05/30/business/30tax. html?_r=2&pagewanted=1&oref=slogin
May 24, 2006 ~ The Wall Street Journal, Review & Outlook: Lost in Taxation
http://online.wsj.com/article/SB114843215721461347. html?mod=opinion%20&ojcontent=otep (subscription required)
May 2006 ~ Baker & McKenzie (North American Compensation and Employment Law Practice Group), Changes to Section 911 Mean Higher Taxes for Some Expatriates
http://www.bakernet.com/NR/rdonlyres/BE93C0AA-
BC42-416A-AC87-6048FCC4F377/0/USSection911Cli entAlertMay2006.pdf
December 2005 ~ Escapeartist.com, Foreign Earned Income Exclusion Internal Revenue Code, Section 911 ~ by William Perez
http://www.escapeartist.com/efam/76/Overseas_Tax es.html
June 16, 2003 ~ Dan Mitchell's PBS Commentary on Eliminating Section 911: "When Politicians Get Greedy, America Loses" ~ Streaming Video
www.townhall.com/audio/CONTENT/on_tv/Dan_Mi tchell_PBS_6_16_03.ram
May 20, 2003 ~ National Review Online, By Ed Feulner, Unfair, If You're Over There: France doesn't tax expatriate incomes. Why do we?
http://www.nationalreview.com/nrof_comment/com ment-feulner052003.asp
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CF&P Studies, Releases and Blog Entries
December 19, 2006 ~ Dan Mitchell Wrote: America's
awful worldwide tax system driving some Americans to give up citizenship
December 4, 2006 ~ Dan Mitchell Wrote: Section 911 provision having harsh
impact on U.S. competitiveness
October 19, 2006 ~ Sven Larson Wrote: Some
good news in the Section 911 battle
September 20, 2006 ~ Sven Larson Wrote: The high cost of double-taxing overseas
Americans
July 31, 2006 ~ Rep. Chocola Introduces
Section 911 Reform Bill to Level the Playing Field for Americans Living and Working Abroad
July 25, 2006 ~ Andrew Quinlan Wrote: Rep. Chocola seeks to level the playing
field for Americans working overseas
July 20, 2006 ~ Dan Mitchell Wrote: Bad worldwide tax system reduces jobs for American citizens.
http://www.freedomandprosperity.org/blog/2006-07/ 2006-07.shtml#203
July 14, 2006 ~ Andrew Quinlan Wrote: Grassley's Ill-conceived tax increase hurts overseas Americans.
http://www.freedomandprosperity.org/blog/2006-07/2006 -07.shtml#145
June 2006 ~ CF&P Foundation Study: Making Section 911 Universal is Good Economic Policy and Good Tax Policy
http://www.freedomandprosperity.org/press/p06-20- 06/p06-20-06.shtml
June 20, 2006 ~ CF&P Capitol Seminar with Senator Jim DeMint: Making America More Competitive: Eliminating the Double-Taxation of Americans Who Live and Work Overseas
http://www.freedomandprosperity.org/notice/n20060 620/n20060620.shtml
June 13, 2006 ~ Coalition for Tax Competition: Coalition Applauds Senator Jim DeMint's Leadership on Making Americans More Competitive Overseas
http://www.freedomandprosperity.org/press/p06-13- 06/p06-13-06.shtml
June 1, 2006 ~ Dan Mitchell Wrote: Senate tax provision imposes giant tax hike on Americans trying to compete in low-tax jurisdictions.
http://www.freedomandprosperity.org/blog/2006-06/ 2006-06.shtml#015
May 30, 2006 ~ Dan Mitchell Wrote: Congressional tax provision undermines U.S. competitiveness.
http://www.freedomandprosperity.org/blog/2006-05/ 2006-05.shtml#303
May 24, 2006 ~ Dan Mitchell Wrote: A big worm in the tax cut apple.
http://www.freedomandprosperity.org/blog/2006-05/ 2006-05.shtml#243
May 2005 ~ CF&P Foundation Study: Territorial Taxation for Overseas Americans: Section 911 Should Be Unlimited, Not Curtailed
http://www.freedomandprosperity.org/press/p05-25- 05/p05-25-05.shtml
May 23, 2003 ~ CF&P Applauds President and Congress: Tax Cut Legislation Produces Lower Taxes on Capital and Elimination of Anti-Competitive "Section 911" Provision
http://www.freedomandprosperity.org/press/p05-23- 03/p05-23-03.shtml
May 13, 2003 ~ Senate Tax Bill Raises Taxes on Americans Working Overseas, Harms U.S. Competitiveness
http://www.freedomandprosperity.org/press/p05-13- 03/p05-13-03.shtml
Letters of Support for DeMint Legislation
Coalition for Tax Competition
Center for Freedom and Prosperity
National Tax Payers Union
U.S. Chamber of Commerce
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