The only countries who tax non-residents purely based upon their citizenship (however acquired) are the United States and Eritrea. I do not consider Eritrea, a brutal one-party dictatorship, a serious country. Further, Eritrea only imposes a 2% tax on citizens abroad, as opposed to the United States, which taxes citizens who have never set foot in the United States (for example, those born to U.S. citizen parents living abroad who never returned to the U.S.) on exactly the same basis as citizens living and working within their territory. The Philippines used to tax based on citizenship, but abolished that system in 1996.
The system of residence-based taxation used by every other country in the world simply requires someone (whether a citizen or not) who leaves the country to file a declaration that they are nonresident, pay taxes for the partial year of residence, and not perform any act which indicates they have resumed residence. If, for example, a UK citizen takes a job with a subsidiary of a UK company in the U.S., moves his family, sells his residence in the UK, ,and only goes back for occasional visits to the home office and family in the old country, they should have no problems at all. If they were to spend more than a certain amount of time in the UK to trigger the residence test, then they would be subject to UK taxation, but for a genuine expat living abroad, that shouldn’t be the case.
The U.S. system is fundamentally different and morally repugnant. It asserts that somebody who is a U.S. citizen, which they may have become purely by being born within its borders, is in a real sense, the property of their government and required to disclose every detail of their financial life to its tax authorities and file these details every year, even though they have left the country, own no property in it, earn no income from any source within it, never travel to it, and have no connections with it, and (for example, due to a dual taxation treaty with their country of residence) owe it no taxes. Failure to file a tax return every year is a criminal offence which may result in imprisonment, fines, and civil penalties if they ever set foot in the U.S.
This applies even (and especially) to “accidental citizens” such as former UK prime minister Boris Johnson, who was born in New York while his father was a student at Columbia University. He was only allowed to renounce his involuntarily acquired U.S. citizenship without penalties or requirement to file a lifetime’s tax return and pay back taxes due to his political status with a U.S. ally. A German engineer at Siemens in similar circumstances who only discovered his accidental citizenship when his company wanted to send him to visit a customer in the U.S. would have no such special treatment.
Further evidence of the U.S. “people are property” doctrine is the requirement that male U.S. citizens living abroad are required to register with the U.S. “Selective Service System” (military conscription), even if they are dual nationals and/or accidental citizens, and if they do not, they are subject to the same civil and criminal penalties as those living in the U.S.
