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
... election . Under this election , taxpayers would be able to treat high gain assets , throwing off little current income as taxable by the United States following expatriation , while they would treat low - gain assets throwing off ...
... election . Under this election , taxpayers would be able to treat high gain assets , throwing off little current income as taxable by the United States following expatriation , while they would treat low - gain assets throwing off ...
Pagina 15
... election . Mr. KIES . No. If somebody makes the election to continue to be taxed on these assets and they are a citizen of another country that also taxes the same income , they are going to owe income tax in both countries . And ...
... election . Mr. KIES . No. If somebody makes the election to continue to be taxed on these assets and they are a citizen of another country that also taxes the same income , they are going to owe income tax in both countries . And ...
Pagina 28
... election as provided in Senator Moynihan and Senator Bradley's bill . That is the appropriate policy to deal with this issue . Senator GRAHAM . Mr. Chairman , I would like to ask permission to insert in the record at this point an ...
... election as provided in Senator Moynihan and Senator Bradley's bill . That is the appropriate policy to deal with this issue . Senator GRAHAM . Mr. Chairman , I would like to ask permission to insert in the record at this point an ...
Pagina 33
... election as provided in Senator Moynihan and Senator Bradley's bill . So that is how we think you have to deal with the problem . Otherwise , we are going to be forever chasing the next tax planning idea , and it is very difficult to ...
... election as provided in Senator Moynihan and Senator Bradley's bill . So that is how we think you have to deal with the problem . Otherwise , we are going to be forever chasing the next tax planning idea , and it is very difficult to ...
Pagina 58
... election would permit long - term residents to determine the tax basis of certain assets using their fair market value at the time the individual became a U.S. resident , rather than their historical cost . The election , if made ...
... election would permit long - term residents to determine the tax basis of certain assets using their fair market value at the time the individual became a U.S. resident , rather than their historical cost . The election , if made ...
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Termeni și expresii frecvente
Administration proposal apply avoiding U.S. taxes capital gains tax CHAIRMAN citizen or resident citizenship or residency current law estate and gift estate tax exemption expatriate's expatriating act expatriation proposals expatriation tax provisions fair market value foreign corporation gain recognition agreement gift tax green card incentive to expatriate individual's intent interest international human rights international law issue JCT Report Joint Committee staff KIES long-term residents loss of citizenship loss of U.S. Means Committee bill million modified bills nonresident aliens pay tax present law principal purpose revenue estimates Secretary SAMUELS section 877 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 taxpayer transfer Treasury Department treated as U.S. trust U.S. citizens U.S. citizenship U.S. income tax U.S. person U.S. residency U.S. source income United unrealized gains USCo visa
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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...
Pagina 41 - Under this rate schedule, the unified estate and gift tax rates begin at 18 percent on the first $10,000 in cumulative taxable transfers and reach 55 percent on cumulative taxable transfers over $3 million.