Tax Treatment of Expatriated Citizens: Hearing Before the Committee on Finance, United States Senate, One Hundred Fourth Congress, First Session, on S. 453, S. 700, H.R. 831, H.R. 981, H.R. 1535, and H.R. 1812, July 11, 1995, Volumul 4U.S. Government Printing Office, 1997 - 118 pagini |
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Pagina 10
... expatriation proposal assumed that expatriating individuals incurred no U.S. tax liability follow- ing the act of expatriation . As a result of our study , we have concluded that expatriating in- dividuals in certain circumstances ...
... expatriation proposal assumed that expatriating individuals incurred no U.S. tax liability follow- ing the act of expatriation . As a result of our study , we have concluded that expatriating in- dividuals in certain circumstances ...
Pagina 19
... expatriate who have been reading that guide book . It does not really take that long to accomplish everything necessary to expatriate ... act is taken which does not necessarily have to be the act of going into a consulate . Therefore , under ...
... expatriate who have been reading that guide book . It does not really take that long to accomplish everything necessary to expatriate ... act is taken which does not necessarily have to be the act of going into a consulate . Therefore , under ...
Pagina 20
... acts that occur within 5 years prior to expatriation . This regulatory author- ity was given to try to catch people who were planning tax avoid- ance techniques before they expatriated . Under the regulatory authority , as I understand ...
... acts that occur within 5 years prior to expatriation . This regulatory author- ity was given to try to catch people who were planning tax avoid- ance techniques before they expatriated . Under the regulatory authority , as I understand ...
Pagina 21
... expatriating each year generally is a relatively small num- ber . It would pick up some money but it would not be a ... acts of expatriation . Senator GRASSLEY . Well , why should we grant the $ 600,000 ex- emption ? Mr. KIES . I think ...
... expatriating each year generally is a relatively small num- ber . It would pick up some money but it would not be a ... acts of expatriation . Senator GRASSLEY . Well , why should we grant the $ 600,000 ex- emption ? Mr. KIES . I think ...
Pagina 25
... expatriation , an expatriating act and an intent to relin- quish citizenship must be proved by a preponderance of the evi- dence . We also hold that when one of the statutory expatriating acts is proved , it is constitutional to presume ...
... expatriation , an expatriating act and an intent to relin- quish citizenship must be proved by a preponderance of the evi- dence . We also hold that when one of the statutory expatriating acts is proved , it is constitutional to presume ...
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Administration proposal amendment to H.R. apply avoid U.S. tax beneficiary capital gains tax CHAIRMAN citizen or resident citizenship or residence current law diploma tax estate tax exemption expatriate's expatriating act expatriating individual expatriation proposals expatriation tax provisions fair market value foreign corporation gift tax green card human rights incentive to expatriate individual's interest international human rights international law issue JCT Report Joint Committee staff KIES long-term residents loss of citizenship Means Committee bill million modified bills nonresident aliens override pay tax present law principal purpose revenue estimates rules Secretary SAMUELS section 877 Senate amendment Senator BRADLEY Senator GRAHAM Senator GRASSLEY Senator Moynihan Senator SIMPSON subject to tax subject to U.S. tax avoidance tax liability tax on expatriation tax on unrealized tax treaties taxable taxpayer terminate transfer Treasury Department trust U.S. citizens U.S. citizenship U.S. income tax U.S. person U.S. residency U.S. source income United unrealized gains