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AMERICAN UNIVERSITY LAW REVIEW
[Vol. 65:1
dependencies, overseas territories, and newly-independent colonies. Of course, tax imperialism and other forms of economic subordination are by no means creatures of the past or limited to situations of quasi-colonial territorial control: they are features of North-South relations that remain ubiquitous." Thus, there is much to learn from the Puerto Rican experience. This Article proceeds in three parts. Part I introduces the concept of tax imperialism and situates it within the broader literature on economic imperialism. Part II engages in a robust historical and legal analysis to construct a detailed account of U.S.-Puerto Rican political and economic relations. Specifically, this Part focuses on the major U.S. tax and economic policies that have impacted Puerto Rican development, identifying in the process three distinct stages of U.S. tax imperialism with respect to the island. Part III considers the ways in which a more broadly applicable theory of tax imperialism might help us to understand the complex relationships between more and less powerful taxing authorities. This Article concludes by stressing the need for Puerto Rican economic self-sufficiency in the future. I.
A THEORY OF U.S. TAX IMPERIALISM
Imperialism is generally defined as an ongoing process of aggressive state action to exert control over another nation." Throughout history, states have used military intervention to achieve such control. But in the modern age of neocolonialism, states have used less formal, but nonetheless invasive, mechanisms to gain influence over target nations' cultural, economic, and legal affairs." As dependency theory underscores in its rejection of modernization theory,"
43. For a detailed discussion of economic policies that have negatively impacted the global South, see generally JOSEPH E. STIGLITZ, GLOBALIZATION AND ITS DISCONTENTS (2002). 44. See generally, e.g., J.A. HOBsoN, IMPERIALISM: A STuDY (5th ed. Ann Arbor ed., 1978) (explaining in detail imperialism and its history); VLADIMIR I. LENIN, IMPERIALISM, THE HIGHEST STAGE OF CAPITALISM (1917) (critiquing imperialism). 45. See, e.g.,JEAN-PAUL SARTRE, COLONIALISM AND NEOCOLONIALISM 1-15 (Azzedine Haddour et al. trans., 2001) (setting forth Sartre's analysis of colonialism and neocolonialism, and arguments for decolonization). 46.
See DAVID E. APTER, RETHINKING DEVELOPMENT: MODERNIZATION, DEPENDENCY,
AND POSTMODERN POLITICS 7-11 (1987) (explaining modernization theory, and arguing that it is important despite being a confusing and constantly changing concept); see also Rumu Sarkar, Critical Essay: Theoretical Foundationsin Development Law: A Reconciliation of Opposites?, 33 DENV. J. INT'L L. & POL'Y 367, 367-68 (2005) (acknowledging the historical tensions between modernization theory and dependency theory); Jane Kaufman Winn, Book Review, How to Make Poor Countries
