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 4
U. S. Congress, Senate Committee on Finance Staff, United States. Congress. Senate. Committee on Finance, United States
U.S. Government Printing Office, 1997 - 118 pagini
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able addition Administration proposal agreement aliens allow amendment American amount apply appreciation assets basis believe beneficiary capital certain Chairman considered continue current law deemed determined earnings effective election estate tax estimates example exemption expatriation tax provisions foreign corporation former gains gift human rights imposed incentive included income tax individual individual's interest international law issue JCT Report Joint Committee staff Kies long-term residents lose Means Committee bill million modified motive override period permanent person planning potential present law principal purpose prior problem raise reason recent recognized regard relinquished renounce respect result rules SAMUELS Second Secretary section 877 Senator subject to U.S. substantial tax avoidance tax treaties taxable taxation taxpayer terminate transaction transfer Treasury Department trust U.S. citizens U.S. citizenship U.S. income U.S. residency U.S. source income U.S. tax United unrealized gains wealthy
Pagina 109 - Everyone has the right to freedom of movement and residence within the borders of each state. 2. Everyone has the right to leave any country, including his own, and to return to his country.
Pagina 110 - The above-mentioned rights shall not be subject to any restrictions except those which are provided by law, are necessary to protect national security, public order (ordre public), public health or morals or the rights and freedoms of others, and are consistent with the other rights recognized in the present Covenant.
Pagina 109 - No one shall be imprisoned merely on the ground of inability to fulfil a contractual obligation. Article 12 1. Everyone lawfully within the territory of a State shall, within that territory, have the right to liberty of movement and freedom to choose his residence.
Pagina 49 - Is a national; or (ii) solely to develop and direct the operations of an enterprise in which he has invested, or of an enterprise In which he is actively In the process of investing, a substantial amount of capital...
Pagina 40 - Interest, dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, and other fixed or determinable annual or periodical gains, profits, and Income...
Pagina 109 - ARTICLE 29 1. Everyone has duties to the community in which alone the free and full development of his personality is possible. 2. In the exercise of his rights and freedoms, everyone shall be subject only to such limitations as are determined by law solely for the purpose of securing due recognition and respect for the rights and freedoms of others and of meeting the just requirements of morality, public order and the general welfare in a democratic society. 3. These rights and freedoms may in no...
Pagina 108 - Everyone has the right to the protection of the law against such interference or attacks. ARTICLE 13 1. Everyone has the right to freedom of movement and residence within the borders of each state.
Pagina 83 - US tax based on the expatriate's probable income for the taxable year, then the expatriate has the burden of proving that the loss of citizenship did not have as one of its principal purposes the avoidance of US income, estate or gift taxes.
Pagina 51 - ... is recognized at that time, generally without regard to provisions of the Code that would otherwise provide nonrecognition treatment. The net gain, if any, on the deemed sale of...