Document Type



Tax Law


For many years, less developed countries (LDCs) have experienced an emigration of their skilled workers to developed countries (DCs), a phenomenon known as the “brain drain”. In response to this issue, Professor Jagdish Bhagwati has proposed a tax on the earnings of professionals, technicians, and kindred persons (PTKs) who emigrate to DCs. This chapter discusses Bhagwati’s proposal, and some alternative proposals. Part 1 explains the “brain drain” problem. Part 2 examines the three main approaches of taxing emigrant PTKs, discusses jurisdictional issues, relief from double taxation, and administrative concerns that arise from these approaches. This section further analyzes Bhagwati’s proposal by examining the United States tax system. Additionally, two potential approaches administered by the United Nations are discussed: (1) a tax on emigrant PTKs, and (2) an assessment on DCs based on the benefits received from their immigrant PTKs. The chapter concludes by determining that a special tax on PTKs is not a feasible option due to major administrability concerns, and an expected lack of participation by DCs.

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