The circumstance where U.S. citizens living and working abroad face tax obligations in both their country of residence and the United States is a persistent concern. This situation arises due to the U.S. system of citizenship-based taxation, where income is taxed regardless of where it is earned. As an example, an American engineer working in Germany may be required to pay income taxes to both the German government and the U.S. Internal Revenue Service.
Addressing this issue holds considerable importance for several reasons. It can alleviate financial burdens on Americans residing overseas, potentially stimulating economic activity and investment. Historically, attempts to reform international taxation have been complex, involving considerations of international treaties, tax law revisions, and potential impacts on government revenue. The Foreign Account Tax Compliance Act (FATCA), while aimed at preventing tax evasion, has also contributed to the complexities faced by Americans abroad.