The article establishes a novel generalization concerning the placement of arguments by Spell-Out. It centers on the principles that force arguments to leave the VP across languages. The empirical domain consists of constructions where subject movement is not required for reasons that have to do with the Extended Projection Principle. In these environments and whenever a sentence contains both a subject and a direct object, one of the arguments must vacate the VP. We argue that argument externalization is related to Case. It is forced because movement of both arguments to a single head T0 that contains two active Case features in the covert component is banned.