 | United States. Congress. Senate. Committee on Finance - 1954 - 662 pagini
...reincorporation, it seems a little harsh to put upon the taxpayer the burden of proving that such transaction did not have as one of its principal purposes the avoidance of tax. Perhaps the problem is only theoretical, but after the passage of a year or two it would seem that... | |
 | United States. Congress. Senate. Committee on Finance - 1954 - 1186 pagini
...reincorporation, it seems a little harsh to put upon the taxpayer the burden of proving that such transaction did not have as one of its principal purposes the avoidance of tax. Perhaps the problem is only theoretical, but after the passage of a year or two it would seem that... | |
 | United States. Congress. House. Committee on Ways and Means - 1967 - 1204 pagini
...established, then the administrator of the expatriate's estate must carry the burden of proving that the loss of citizenship did not have as one of its principal purposes the avoidance of US income, estate, and gift taxes. (d) Effective date. — This new provision is effective... | |
 | United States. Congress. Internal Revenue Taxation Joint Committee - 1967 - 66 pagini
...established, then the administrator of the expatriate's estate must carry 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. Effective date. — This new provision is effective... | |
 | United States. Tax Court - 1980 - 1358 pagini
...have us bifurcate respondent's ruling into two freestanding conclusions: (1) The proposed liquidation did not have as one of its principal purposes the avoidance of tax, and (2) the requirement that the US parent include in its income the undistributed current and accumulated... | |
 | 1995 - 386 pagini
...burden of showing that either these factors did not exist, or that even though these factors did exist, the loss of citizenship did not have as one of its principal purposes the avoidance of taxes. The IRS also has not attempted to exercise any regulatory authority, nor has it... | |
 | United States. Congress. Senate. Committee on Finance - 1995 - 452 pagini
...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. Section 877 does not apply to resident aliens who terminate... | |
 | United States. Congress. Senate. Committee on Finance - 1995 - 166 pagini
...If this reasonable belief is established, then the expatriate must carry the burden of proving that the loss of citizenship did not have as one of its principal purposes the avoidance of US income, estate o gift taxes. Under this alternative method, the expatriate generally... | |
 | United States. Congress. Senate. Committee on the Budget - 1995 - 1006 pagini
...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. Section 877 does not apply to resident aliens who terminate... | |
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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. 
