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 32
... transfer all of their U.S. - source assets into a foreign corporation and , as a consequence , the income they then receive from that foreign corporation is treated as foreign- source , not U.S. - source , and , therefore , not subject ...
... transfer all of their U.S. - source assets into a foreign corporation and , as a consequence , the income they then receive from that foreign corporation is treated as foreign- source , not U.S. - source , and , therefore , not subject ...
Pagina 41
... transfer of property by gift made by a U.S. citizen or resident , " whether made directly or indirectly and whether made in trust or otherwise . Nonresident aliens are subject to the gift tax with respect to transfers of tangible real ...
... transfer of property by gift made by a U.S. citizen or resident , " whether made directly or indirectly and whether made in trust or otherwise . Nonresident aliens are subject to the gift tax with respect to transfers of tangible real ...
Pagina 42
... transfer tax is imposed on certain " generation - skipping " transfers . 3 . Special tax rules with respect to the movement of persons and property into or out of the United States a . Individuals who relinquish U.S. citizenship with a ...
... transfer tax is imposed on certain " generation - skipping " transfers . 3 . Special tax rules with respect to the movement of persons and property into or out of the United States a . Individuals who relinquish U.S. citizenship with a ...
Pagina 43
... transfer . A special rule is applied to the estate tax treatment of any decedent who relinquished his or her U.S. citizenship within 10 years of death , if the decedent's loss of U.S. citizenship had as one of its principal purposes a ...
... transfer . A special rule is applied to the estate tax treatment of any decedent who relinquished his or her U.S. citizenship within 10 years of death , if the decedent's loss of U.S. citizenship had as one of its principal purposes a ...
Pagina 44
... transfer are subject to U.S. gift tax , if the loss of U.S. citizenship had as one of its principal purposes a tax avoidance motive.18 b . Aliens having a break in residency status A special rule applies in the case of an individual who ...
... transfer are subject to U.S. gift tax , if the loss of U.S. citizenship had as one of its principal purposes a tax avoidance motive.18 b . Aliens having a break in residency status A special rule applies in the case of an individual who ...
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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.