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Yeah, fair enough, it's legal and I'm sure he has the legal representation to abide by the letter of the law. That said... if I wanted to present a highly sympathetic portrait of someone renouncing US citizenship because of the unusual policy of taxing citizens overseas, this isn't the case I'd pick. I believe that Saverin benefitted tremendously from being in the US, as a US citizen, and that his earnings (ie., proceeds from the IPO) are a direct result of having been in the US for this time. When you work at a startup, you are essentially working for the prospect of future earnings (in a way, it's a form of deferred earnings, except of course it's highly unpredictable). He has found a clever way to be a US citizen while his earnings are unrealized, but not a US citizen once they are. This is very different from the case where a person earning a salary in the US moves overseas and lives and earns a salary as a resident of a different country. By the way, I've never read a real defense of the unusual policy of taxing US citizens who live abroad, and I am a little worried I'm overlooking something here. Does anyone know what the justification for this is? Or why it's justifiable for the US but not (essentially) every other country? |