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 5
... international law regard- ing human rights . It is now clear that those concerns are un- founded . A multitude of experts indicate that the expatriation pro- posals that have been introduced do not violate international human 5.
... international law regard- ing human rights . It is now clear that those concerns are un- founded . A multitude of experts indicate that the expatriation pro- posals that have been introduced do not violate international human 5.
Pagina 7
... regard to taxpayer motivation . Thus , the Adminis- tration proposal would impose tax on U.S. citizens or residents who are expatriating for purely non - tax reasons , those who have long- term dual citizenship with another country to ...
... regard to taxpayer motivation . Thus , the Adminis- tration proposal would impose tax on U.S. citizens or residents who are expatriating for purely non - tax reasons , those who have long- term dual citizenship with another country to ...
Pagina 11
... regard to their motive for expatriating . Accordingly , a wealthy expatriate who transfers all of his or her assets to a foreign corporation he or she controls and who dies within 10 years of expatriation generally gnerally pay no ...
... regard to their motive for expatriating . Accordingly , a wealthy expatriate who transfers all of his or her assets to a foreign corporation he or she controls and who dies within 10 years of expatriation generally gnerally pay no ...
Pagina 15
... regard to the time . So you cannot kind of beat Senator Moynihan's bill by waiting 10 years . Thus , that person does not have the problems that Mr. Kies raised , and that provi- sion was put in specifically by Senator Moynihan to deal ...
... regard to the time . So you cannot kind of beat Senator Moynihan's bill by waiting 10 years . Thus , that person does not have the problems that Mr. Kies raised , and that provi- sion was put in specifically by Senator Moynihan to deal ...
Pagina 25
... regard , it really does become a really fundamental issue of fairness and one in which , quite frankly , again , the volun- tariness issue is not an issue because the court - and the President makes it very clear - you really have to go ...
... regard , it really does become a really fundamental issue of fairness and one in which , quite frankly , again , the volun- tariness issue is not an issue because the court - and the President makes it very clear - you really have to go ...
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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 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. real property 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.