36 Ga. L. Rev. 835 (2001-2002)
Giving Taxpatriates the Boot--Permanently: The Reed Amendment Unconsitutionally Infringes on the Fundamental Right to Expatriate; Carter, Michelle Leigh

handle is hein.journals/geolr36 and id is 855 raw text is: GIVING TAXPATRIATES THE
BOOT-PERMANENTLY?: THE REED
AMENDMENT UNCONSTITUTIONALLY
INFRINGES ON THE FUNDAMENTAL RIGHT
TO EXPATRIATE
I. INTRODUCTION
The life story of an unnamed man is told in a detailed letter
written by his accountant to the Internal Revenue Service.' He was
born in India to Chinese parents.2 He grew up in Calcutta and went
to work for the Bank of China's Calcutta branch, yet he maintained
his Chinese citizenship and traveled on a Chinese passport.3
Following World War II, the bank sent him to work for one of their
branches in Pakistan.4 After China fell to the Communists, he
refused to become a citizen of the People's Republic of China.5
Having no nation, he relinquished his Chinese passport and became
a Pakistani citizen.6 He then married a woman of Chinese descent,
born in India, and consequently a citizen of both China and India.'
He soon began to work for a Bermuda-registered insurance company
located in Pakistan.8
His work for the insurance company led him to Hong Kong, and
eventually his citizenship changed again.9 The corporation was
reluctant to have someone from Pakistan sitting on its board, so he
See Barry Newman, Taxing Issue: How Do You Quit Being an American? With Great
Difficulty: As Many Expatriates Learn, Renouncing Citizenship is Harder than Ever, WALL
ST. J. EUR., Dec. 30, 1998, at 1 (recounting facts of letter from accountant to Internal Revenue
Service pleading for more lenient judgment on client ruled to have expatriated for tax
avoidance reasons). The IRS released the letter for publication on the Internet because it
served as a comment on the law. Id.
2 Id.
3 Id.
4 Id.
5 Id.
6 Id.
7 Id.
a Id.
9 Id.

835

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