From: Duncan Frissell <frissell@panix.com>
Date: Sun, 28 Apr 1996 14:45:39 +0800
To: Michael Froomkin <froomkin@law.miami.edu>
Subject: Re: US law - World Law - Secret Banking
Message-ID: <2.2.32.19960428005703.00d22650@panix.com>
MIME-Version: 1.0
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At 02:43 PM 4/27/96 -0400, Michael Froomkin wrote:
>I disagree with the assertion that a hypothetical 2 yr old with a US 
>passport who never set foot in the US again gets nothing for her 
>citizenship.  The evidence is that she didn't rennounce it: if was 
>worthless to her she could easily do so.
>

She need not ever have even gotten a US passport.  Additionally, she
probably can't renounce her citizenship until she reaches majority.  Also,
if she is born with a fortune and the Clinton Exit Tax (which declares that
renunciation of citizenship is a taxable event) is in place, she is out vast
quantities of cash for nothing.  The problem is the US tax system which
tries to maintain an extra-territorial reach and encourages renunciation of
citizenship.

DCF