Model Charter of Taxpayer Rights

A consortium of tax advisors has prepared a "Model taxpayer charter to promote greater fairness in taxation across the world".  They have sent copies of this model charter to "Ministers and Deputy Ministers of Finance and Revenue of the countries who participated in the survey alongside the institutions of the European Union, the OECD, the United Nations Fiscal Affairs Committee, the World Bank, the IMF, and other interested stakeholders."

I feel like an interested stakeholder, but it appears that the draft is only available....for sale on amazon....specifically, amazon.uk. That's one very strange way to try to make global tax policy.

If anyone knows anything about this project, I would like to hear more about it.

Call for Papers on Securities Litigation-of interest to those working on corporate tax transparency.

Securities regulations are near and dear to the hearts of tax practitioners and accountants who must deal with tax disclosures required in SEC filings.  Perhaps these regs have been less central to the work of tax law academics, but those of us following the extractive industries transparency initiative in particular (since it is already law) and country-by-country reporting more generally may soon find ourselves immersed in SEC compliance and litigation research. This upcoming workshop in Chicago could be a good opportunity to make some progress--paper submissions are due May 31:

The University of Illinois College of Law and the University of Richmond School of Law invite submissions for the First Annual Workshop for Corporate & Securities Litigation.  This workshop will be held on Friday, November 8, 2013, in Chicago, Illinois. 

OVERVIEW: This annual workshop will bring together scholars focused on corporate and securities litigation to present their works-in-progress.  Papers addressing any aspect of corporate and securities litigation or enforcement are eligible.  Appropriate topics include, but are not limited to, securities litigation, fiduciary duty litigation, or comparative approaches to business litigation.  We welcome scholars working in a variety of methodologies, including empirical analysis, law and economics, law and sociology, and traditional doctrinal analysis. 

Authors whose papers are selected will be invited to present their work at a workshop hosted by the University of Illinois College of Law in Chicago, Illinois, on Friday November 8, 2013. Local costs (lodging and workshop meals) will be covered.  Participants are asked to pay for their own travel expenses.
The workshop is designed to maximize discussion and feedback. All participants will have read the selected papers.  The author will provide a brief introduction to the paper, but the majority of the individual sessions will be devoted to collective discussion of the paper involved. 

SUBMISSION PROCEDURE: If you are interested in participating, please send an abstract of the paper you would like to present to Jessica Erickson at jerickso@richmond.edu  not later than Friday, May 31, 2013.  Please include your name, current position, and contact information in the e-mail accompanying the submission. Authors of accepted papers will be notified by Friday, June 28. 

QUESTIONS: Any questions concerning the workshop should be directed to the organizers—Professor Verity Winship (vwinship@illinois.edu) and Professor Jessica Erickson (jerickso@richmond.edu).

How To Chart Good

Having seen all too many charts that have been labored over in vain by students, academics, and practitioners alike, this resonates.

Irony: it's often difficult to communicate with charts, yet this one does a beautiful job.

Correcting the record 5 ways on the stories about Sen. Paul blocking "FATCA Treaties"

Just to clarify a few matters, now that I see the Hill has picked up on this idea that somehow Senator Rand Paul is blocking something the folks at Global Financial Integrity are calling "FATCA implementation treaties":

1) There is no such thing as a FATCA implementation treaty.  There are things called "intergovernmental agreements" (IGAs) which the US has been signing with some countries, which override FATCA, making the unilateral statute less onerous than it otherwise would be.  Anyone who is "pro" anti-evasion legislation (is there anyone who isn't?) can be wildly enthusiastic about FATCA, more or less enthusiastic about IGAs (perhaps less since they tend to water FATCA down), and basically uninterested in double tax conventions, which do almost nothing to combat tax evasion. Conversely, anyone who doesn't like FATCA can be enthusiastic about IGAs because they water down FATCA and leave more room for non-compliance, and wildly enthusiastic about double tax treaties, since they do nothing, FATCA-wise.

2)  Double tax conventions are not needed to implement FATCA.  FATCA is a domestic US statute which needs no implementing anything of any kind. It is already the law, it is already in force, and it is already in action.  So let us put to rest any notion that any international agreement could have any impact on the implementation of FATCA. FATCA is going to be difficult to enforce, no question about that. But it is existing law.  Its administrative and above all political difficulties are what have led Treasury--after FATCA was already law--to start thinking about asking for help.

3) Double tax conventions are not needed to implement IGAs.  The IGAs are Treasury's way of reducing the administrative and political burden Congress created for it with FATCA. An IGA would override the FATCA statute to make life easier for both the Treasury and foreign banks. But the IGAs are most certainly not treaties, in fact, just what exactly they are is muddled indeed.  Treasury has suggested that to the extent the US undertakes anything in these IGAs (which is precious little, at best), they are "interpretive" in nature that is, they interpret existing tax treaties. Hence perhaps some confusion: if you want an IGA which involves the US giving you anything back, Treasury is suggesting you may need a treaty for the IGA to "interpret." To be sure, the idea that IGAs are interpretive in nature is a stretch: IGAs are really just sole executive agreements. Treasury is not seeking any kind of congressional approval for them. Therefore no one in congress-Sen Paul or otherwise-can block them by holding up any kind of international agreement. The only way to block an IGA would be through a direct challenge to their legitimacy given that they violate the treaty power, which is supposed to be shared with the senate. Perversely, perhaps, if the IGAs were legitimate treaties, they could be blocked by Sen. Rand. But they are not, so they cannot be.

4) Switzerland already has a double tax treaty with the USA so even if the Switzerland IGA was the kind that theoretically needs a DTT to "interpret" (namely, a Model 1-style), the treaty needed is already in place, with language on information sharing ready to be "interpreted" by an IGA. However, Switzerland has not signed a Model 1 IGA with the US, it has signed a so-called "Model 2" IGA, which is non-reciprocal and binds the US to virtually no action whatsoever. It is for this reason, perhaps, that Treasury has already claimed that Model 2 agreements do not even need a treaty to interpret: that is, the Treasury has suggested that even non-treaty countries can get a Model 2 IGA.  So you never need a treaty with Switzerland to implement the proposed IGA.  Blocking the Swiss treaty may do a lot of things, but stopping the FATCA IGA is most certainly not one of them

5) Hungary and Luxembourg also already have DTTs in place. They are both old (Hungary-1979, Lux-1962) but each has info exchange language (Hungary-art 23, Lux art 28) so Treasury could again "interpret" these with an IGA, again by the logic that the IGAs are interpretive in nature. Of course, there is no IGA yet for Hungary that I know of, and Luxembourg is still mulling things over. If either goes with model 1, fine, DTT already in place. If they go with model 2, see above re Switzerland. Therefore there is no blocking of FATCA, an no blocking of FATCA IGAs, with respect to either of these countries, either.

Summary: IGAs are wholly unconnected to DTTs. The mistaken connection being made between these two completely unrelated legal instruments is understandable: it has been borne of Treasury's attempt to cast the IGAs as interpretive in nature, which at best is an ad hoc attempt to fix a legal impossibility of congress' own creation, without actually explaining their legal pedigree.  But DTTS are in no way necessary to the implementation of FATCA.

Call for Papers: Annual Conference of the Canadian Council of International Law

The organizers of the CCIL's 2013 annual conference have issued a call for papers:

CCIL 42nd  Annual Conference: Call for Papers
Contemporary Actors and their Actions: A New Look at the Formation of International Law
November 14-16, 2013 - Ottawa, Ontario

The Canadian Council on International Law invites paper proposals or summaries of proposed presentations from faculty members, doctoral level graduate students in law and related disciplines, and practitioners, on topics dealing with the theme of its 42nd Annual Conference: “Contemporary Actors and their Actions: A New Look at the Formation of International Law”.

Paper proposals or summaries of proposed presentations in English or French should be no longer than a single page in length and should include a biographical statement or curriculum vitae.  Proposals are due June 3, 2013 and should be sent to manager@ccil-ccdi.ca.

Great topic. More info at the link.

CTF Conference on Tax & Employee Mobility-McGill Law School, May 29 2013

Si vous avez de la difficulté à lire ce courriel, s.v.p. visionner la version en ligne. Afin de vous assurer de bien recevoir nos courriels, ajouter ctf-fcf@ctf.ca à votre carnet d'adresses.

Bureau 2935 1250, boul. René-Lévesque ouest Montréal, QC H3B 4W8 Téléphone : (514) 939-6323 Télécopieur : (514) 939-7353 Inscrivez-vous avant le 4 mai pour profiter du tarif "oiseau matinal" Journée d'études fiscales Mobilité des employés à l'étranger (English below) Le mercredi 29 mai 2013 8 h 20 à 16 h 45 Suivi d'un cocktail gracieusement offert par Stikeman Elliott Université McGill, Faculté de droit 3644 rue Peel Montréal [Inscrivez-vous en ligne] [Formulaire d'inscription - PDF] inscrire à votre agenda Cette année et dans le cadre de la Journée d'études fiscales, la Fondation canadienne de fiscalité a choisi de présenter des conférences ayant pour thème les Canadiens qui travaillent temporairement ou de façon permanente à l'étranger. Plusieurs aspects de la fiscalité seront abordés, tant du point de vue de l'employé que du point de vue de l'employeur, par des experts en la matière. Les faits saillants de la Journée d'études fiscales comprennent : (certaines présentations seront en anglais) • Les aspects fiscaux pour l'employé et pour la société (employeur)                  > impact sur les régimes de retraite et autres régimes de rémunération                  > frais de localisation du ou vers le Canada                  > planification du rapatriement                  > mécanisme de compensation salariale (tax equalization)                  > impôt au décès ou impôt sur les successions • Utilisation d'une société particulière pour « services d'employé »                  > exemple de mécanismes d'opération                  > bénéfices potentiels et éléments fiscaux à considérer • Éléments fiscaux à considérer lors d'un transfert dans un pays émergeant • Aspects administratifs à considérer                  > Retenues à la source                  > Mécanismes de recharge intragroupe • Visa et autres aspects légaux à considérer Pour consulter le programme ou pour vous inscrire s.v.p. cliquez ici. Pour toutes informations supplémentaires s.v.p. contactez le bureau de Montréal au 514 939 6323 ou par courriel à adminmtl@ctf.ca   Prochains événements : Le mardi 14 mai 2013: TAX STRATEGIES FOR EXECUTIVE COMPENSATION (en anglais) (Ottawa) (demi-journée) Le jeudi 16 mai 2013: FAIRE AFFAIRE AUX ÉTATS-UNIS : STRUCTURES DE FINANCEMENT AMÉRICAINES (Québec) (demi-journée) Pour les jeunes fiscalistes: Le vendredi 10 mai 2013: PERTES SUPENDUES (Midi-conférence) (Montréal) Le jeudi 30 mai 2013: ACTIONS ACCRÉDITIVES (Petit-déjeuner fiscal) (Québec) FONDATION CANADIENNE DE FISCALITÉ ***** Register before May 4th to benefit from the Early Bird rate  Journée d'études fiscales Employee Mobility - Assignments Abroad  Wednesday, May 29, 2013  8 :20 a.m.  –  4 : 45 p.m. Followed by a cocktail reception sponsored by Stikeman Elliott  McGill University, Faculty of Law 3644 Peel Street Montréal [Register online] [Registration form - PDF] (Take advantage of our early bird rate by registering before May 3rd, 2013) add to calendar This year, the theme for the Canadian Tax Foundation's annual Journée d'études fiscales, is employee foreign assignments. Speakers at this conference will be discussing the various taxation considerations which arise, both from the perspective of the employee and of the employer, when Canadians choose to temporarily or permanently move their place of work abroad. Various aspects of taxation will be analyzed during the course of the day by experts in the field. Topics covered at the Journée d'études fiscales will include: (certain presentations will be in English) • Tax considerations for the employee and employer corporation            > Impact on retirement savings vehicles            > Cost of relocation to or from Canada            > Planning the repatriation            > Tax equalization            > Death and inheritance taxes • Using a special purpose corporation for employee services           > Examples of methods of operation           > Potential benefits and taxation considerations • Taxation issues when considering a move to a developing country • Administrative issues to consider          > Source deductions          > Mechanisms for intra-group charge back • Visas and other legal considerations To consult the program or to register, please click here. For any additional information, please contact the Montréal office at 514 939 6323 or by email at adminmtlctf.ca

Recent academic scholarship on FATCA

It seems to me that academic attention to FATCA is on the rise. Here is a roundup of recent lectures & publications by law professors (and one student):

Steven Dean delivered a lecture at the University of Antwerp entitled FATCA's Unanswered Questions, description:

Like an asteroid passing close to Earth, the threat of FATCA's implementation has caused great anxiety and much activity. Despite the existence of important questions about FATCA's implementation, it has caused even some of the most reluctant foreign governments to embrace information reporting obligations. Tracing FATCA's origins offers useful insights regarding its likely effects. Even if it ultimately "misses" as a commitment device, FATCA will have a lasting impact on global tax administration.

Susan Morse published a reply to my article on the dubious legal pedigree of FATCA agreements, entitled Why FATCA Intergovermental Agreements Bind the U.S. Government, abstract:

Bilateral intergovernmental agreements (IGAs) relating to the Foreign Account Tax Compliance Act (FATCA) and entered into by the U.S. government reduce the reach of FATCA's withholding tax regime, including the reach of that regime as applied to non-U.S. taxpayers. The validity of these IGAs has been questioned. Yet IGAs have a strong case for binding status as valid congressional-executive agreements or treaty-based agreements. In addition, regardless of IGAs’ status as international agreements, they should bind the U.S. government as valid administrative guidance.

Frederic Behrens (law student) published Using a Sledgehammer to Crack a Nut: Why FATCA Will Not Stand, abstract:

The Foreign Account Tax Compliance Act (FATCA) became law in 2010 and is an important development in combatting income tax evasion. Under FATCA, American individual and corporate taxpayers must provide comprehensive information to the Internal Revenue Service (IRS) regarding foreign bank accounts. In addition, a more controversial part of FATCA requires foreign banks to report directly to the IRS certain information about financial accounts held by American taxpayers. 

These drastic changes in American tax policy are alarming to the international financial community. International banks are forced to implement expensive compliance programs to satisfy the information reporting requirements. An increasing number of foreign financial institutions will no longer want any involvement with American citizens or investments. Furthermore, Americans living abroad might be forced to denounce their American citizenship in order to gain access to insurance and basic banking options.   

In response to the unilateral imposition of FATCA, foreign governments and banks may lobby for its repeal. This Comment examines factors in the global movement to repeal FATCA and suggests several workable solutions that would be agreeable to the United States and foreign nations. Specifically, this Comment suggests how investment income withholding and increased IRS enforcement actions are a better solution to prevent income tax evasion.

And Itai Grinburg delivered a new paper at NYU, entitled Emerging Countries and the Taxation of Offshore Accounts, abstract:

A new international regime in which financial institutions function as cross-border tax intermediaries is emerging. The contours of that regime will be established during a narrow window of opportunity over the span of the next few years. The resulting regime will have especially important consequences for emerging countries. A uniform, multilateral automatic information exchange system would improve both these jurisdictions’ ability to tax the offshore accounts of their residents and their capacity to tax certain domestic-source income from capital. 

Interestingly, multinational financial institutions’ and emerging countries’ concerns with the emerging international regime are largely aligned. As a result, they may find that they are improbable allies in the battle over taxing offshore accounts. With the G-20 as an agenda-setter and international financial law as the model, a governance structure for an automatic information exchange regime that could be useful to emerging countries’ tax administrations and lower multinational financial institutions’ compliance costs could materialize. The paper explores the necessary architecture, as well as steps emerging countries may take to help that architecture develop.

Many different perspectives emerging. Have I missed any recent scholarship? Please do bring it to my attention if so.

Economist: It would be terrible if people stopped depending on their employers for their health care.

Casey Mulligan says if the law actually applies to Congress, look for it to be far too bountiful, in a Speenhamland kind of way (see also Polanyi). The state, it seems, must do all it can to avoid producing healthy shirkers amongst the general populace, even if that requires dispensing a certain amount of injustice. A sad commentary on both human flourishing and the rule of law, is it not?  Excerpts:

To promote economic efficiency and the goal of universal health coverage, perhaps members of Congress should not be required to enroll in the new insurance exchanges.

...Because members of Congress are accustomed to high-quality medical care provided to them through federal employee benefit programs, one might expect that they would push for top quality care to be delivered through the exchanges too.

...If the exchange plans were good enough, people who are rushing to find a job, and people considering leaving their job, would no longer have to see employment as their only means of obtaining top quality, subsidized coverage. As a result, some of those would work less (see the Congressional Budget Office on some of health reform’s work incentives, and a 1994 explanation from Alan Krueger and Uwe E. Reinhardt). 

...Although politically incorrect and perhaps unfair, allowing members of Congress to keep their federal employee coverage might be the best thing for universal coverage and reducing the impact of the Affordable Care Act on the federal budget. 

Why It Would Be Great if Congress Was Forced to Buy Their Own Health Insurance at Full Cost

From FDL, highlights:

Making Congress and their staffers pay the full cost of their insurance is fine with me because that is how the law will treat millions of middle class families. All members of Congress and most staffers will have salaries high enough they would not qualify for subsidies on the exchanges. If Congress is going to make regular people with similar salaries buy insurance out-of-pocket than that should be good enough for Congressional aides.

I also have no problem with the law forcing Congressional staffers to lose their relatively good insurance because that is a long term goal of the law for everyone. The excise tax on “Cadillac coverage” was designed to stop employers from providing good insurance, covering a large share of your premium, and/or getting them to drop offering coverage altogether.  What might happen to Congress is very similar to what Congress intended to happen to others. 

Finally, if Congress is worried their staffers can’t afford to buy insurance out-of-pocket they can just use the money Congress would have spent on their premium and raise their salaries by the corresponding amount. The financing of the law was based on the theory that a dollar in benefits is exactly the same as a dollar in salary. The theory, put forward by Obama’s economists, advisers and the Joint Tax Committee is that if you force companies to offer their employees worse insurance, they will increase their wages by an equal amount. This sounds like a perfect opportunity to put the theory to the test.

Have laws apply to lawmakers the same as it applies to the governed, have the law play out as it was designed, and put the underlying economic theory to the test: these seem like common sense ways to make sure that our democratic decision-making structure is working. Unfortunately we have ample evidence that this structure is working better for lawmakers (and lobbyists) all the time, and correspondingly worse for everyone else.  Congress exempting itself from things that won't personally benefit its members is not a new story, and in light of the brazen roll-back of the "Stop Trading on Congressional Knowledge Act" in order to make it easier for members to quietly line their pockets via insider trading, there is ample reason for pessimism.

Still, WAPO has a story about how Congress isn't really trying to exempt itself, just trying to fix some inadvertent writing in the code that caused some unintended consequence that only a few people understand enough to get upset about. A book could be written on that recurring theme.

What tax lawyers mean when they opine on the likelihood of success on the merits

I posted this on Twitter yesterday but for those not of the twitterverse, you may enjoy this guide to tax opinion standards, posted recently at Canadian Tax Litigation blog:

Percentage chance of success...Standard of Opinion 100% Will
99% Will, at the Ivory Soap level
98% Will, almost certainly
97% Will, almost all the time
96% I would be astounded if we lost
95% I would be very surprised if we lost
94% We will not lose this one
93% It had better be right
92% I would tell my mother-in-law to do this
91% I would tell my mother to do this
90% I would tell your mother to do this
89% Like crossing the street
88% It's in the bag
87% They don't get much better
86% You don't need an opinion
85% Why are you asking the question?
84% It’s almost in the bag
83% One could imagine a "will"
82% Stronger than a strong should
80% Strong should
79% Essentially, a strong should
78% Better view is a strong should
77% Not without hesitation, a strong should
76% Better than a good should
75% Good should
74% Odds are high
73% Remarkably likely
72% Very likely
71% Better than a weak should
70% Weak should
69% We expect to win
68% In all probability
67% In all likelihood
66% Looking good
65% Should probably
64% Most likely
63% Likely
62% Favourable prospect
61% Not without hesitation, should
60% Not a bad prospect
59% Reasonable prospect
58% Fair prospect
57% Well-grounded hope
56% There is reason to expect
55% Better view
54% Ought to be right
53% Not without hesitation, the better view
52% More likely than more likely than not
51% More likely than not
50% Your guess is as good as mine
49% Less likely than not
48% Less likely than less likely than not
47% Almost there
46% I hesitate to predict
45% Depends on the day of the week
44% If we get the right judge
43% A very good shot
42% A good shot Percentage chance of success Standard of Opinion
41% It arguably could work
40% It arguably might work
39% G-d willing
38% Depending on the facts
37% There are good arguments
36% Could be in the cards
35% Stranger things have happened
34% Throw of the dice
33% As taxpayer's counsel, I would not be ashamed to argue this in court
32% Not without considerable doubt
31% With some good fortune
30% Might
29% Might be argued that
28% Stands a chance
27% Might stand a chance
26% It could be that it might work
25% I might be that it could work
24% Not very likely
23% Conceivably
22% Conceivably, but not hopeful
21% I've seen worse
20% Perhaps arguable
19% Within the bounds of possibility
18% Maybe
17% Maybe, but not likely
16% Not likely enough
15% Possible, but not likely
14% Maybe Enron would do this
13% As a DOJ lawyer, I would not be ashamed to argue this in court
12% It should work, but it won't
11% It could work, but it won't
10% It might work, but it won't
9% Tell them you didn't know
8% Perhaps if nobody finds it
7% You have got to be joking
6% Anything can happen, but this won't
5% You must not understand the legislation
4% Canadian jails aren't bad
3% I wouldn't wish it on my enemies
2% Not bloody likely
1% Not in a month of Sundays
0% Not 

Corporate tax transparency: Australia's work in progress

Australia is working on transparency and information sharing, and is seeking feedback by April 24 (this Wednesday):

On 4 February 2013, the Assistant Treasurer announced the Government’s intention to improve the transparency of Australia’s business tax system and that the Government would consider the views of the community in assessing what changes are appropriate. 

The Government seeks your feedback and comments on the issues outlined in this discussion paper. As this paper provides details about how these proposals could be legislated, you may wish to comment on law design as well as policy design issues in your submission. It would assist the consultation process if those stakeholders who have any concerns with the proposals could provide practical examples in their submissions demonstrating the implications of these proposals and how any alternative approaches could operate.

Highlights from the discussion paper:

On 4 February 2013, the Assistant Treasurer announced the Government’s intention to improve the transparency of Australia’s business tax system with a view to introducing necessary legislation later this year. ... 

This paper outlines three proposals that could give effect to this announcement. ...These proposals could complement existing corporate disclosure requirements and enhance the administration and regulation of Australia’s tax system and capital markets. ...

• Transparency of tax payable by large and multinational businesses. 

– The objective of this proposal is to enable the public to better understand the corporate tax system and engage in tax policy debates, as well as to discourage aggressive tax minimisation practices by large corporate entities. 

• Publishing aggregate collections for each Commonwealth tax. 

– The objective of this proposal is to enable better public disclosure of aggregate tax revenue collections, even when the identity of particular entities could potentially be deduced. 

• Enhanced information sharing between Government agencies. 

– The objective of this proposal is to build on existing information sharing arrangements and enable greater information sharing between the Australian Taxation Office (ATO) and the Department of the Treasury with respect to foreign acquisition and investment decisions affecting Australia.

Australia's Treasury seeks to consider views from "the community"--not defined so no reason that can't mean the global community.  Address written submissions to: 

General Manager
Tax System Division
The Treasury
Langton Crescent
PARKES ACT 2600

TaxTransparency@treasury.gov.au

Thanks to Miranda Stewart for passing this along.

The Boundaries of Tax Justice

I posted a draft of this paper on SSRN some time ago but neglected to post it here, so here it is. I argue that because governments chase wage-earners and consumers doggedly while selectively overlooking or ignoring other taxpayers, the imposition of income taxation as it is practised by states today is fundamentally unjust. Abstract:

The story of our time may be the awakening of society to an epidemic of global tax dodging by the world’s elites. Citizens, watchdog groups, and even government officials are puzzled, frustrated, and sometimes outraged by the phenomenon, wondering where the nation-state lost its way in regulating its people and its resources, and why it is standing by, apparently helplessly, as its tax base erodes while austerity measures undermine the welfare state. This paper demonstrates that the sequence of tax base erosion-austerity-welfare state erosion is a story about a crisis of tax justice. It does so by revisiting how Canada's historic Royal Commission on Taxation, in its search for guiding principles for tax reform, turned to tax justice as the central component for any tax system. It shows why nations have consistently failed to meet these guiding principles, instead taxing the easy-to-tax more or less comprehensively, the hard-to-tax more or less randomly, and the impossible-to-tax not at all. It demonstrates that the result is that no state today imposes taxation justly: instead, taxation as exercised around the world today is overwhelmingly characterized by arbitrariness and injustice. The paper concludes that if governments cannot or will not pursue justice in taxation, they have at minimum a duty to explain to society why this goal is no longer worthy of pursuit.

This paper includes a discussion of who should be considered a "taxpayer" by a state. I argue that citizenship-based taxation is unjust from both a human and statist perspective, and I therefore make the case for residence-based taxation. As always, comments are welcome.