Components
The Accidental American: The case of Boris Johnson
Boris Johnson, former mayor of London and Prime Minister of Great Britain, was a powerful even “rebellious” politician with seven children born to three wives and a mistress (Shone, 2022). Boris had many political successes, including Brexit and guiding the UK through Covid. Yet despite his high level of political clout, while mayor of London he met his match with the US Internal Revenue Service. Boris held US citizenship, as his parents lived briefly in the US when he was born. The United States uses the rare citizenship-based tax system that taxes nonresident citizens on their world-wide income. This allowed the IRS to tax the gain of Boris’ UK residence even though Boris had not lived in the US since the age of five. Boris was adamant he would not pay the US tax.
In completing this assignment, students should be able to:
1. Explain how citizenship is conferred to US citizens.
2. Understand the differences between citizenship-based taxation (CBT) and residence-
based taxation (RBT).
3. Discuss the filing requirements for US citizens living overseas.
4. Evaluate maintaining the CBT model in the US.
5. Examine ways an expatriate can reduce taxes due to CBT.
6. Develop criteria to use when considering US expatriation.