Comment Re:Stupid (Score 1) 825
It's easy.
If a US citizen is in a country where a taxation treaty exists, follow the treaty rules. The US citizen only owes up to the maximum bracket they are in. If they are undertaxed in the foreign country, they get to pay the difference.
If the US citizen's capital should end up in a low tax country, then the US citizen pays the difference following the treaty rules. If the US citizen parks their capital in a non-treaty country, then tax them at the full rate without regard for local tax rates. That will learn them for trying to hide money abroad.