Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ReportU.S. Government Printing Office, 1995 |
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Pagina 4
... U.S. citizen for the period since the expatriating act was committed . It is un- clear whether the United States would have any legal basis for attempting to collect tax in such a case since the individual has lost all rights and ...
... U.S. citizen for the period since the expatriating act was committed . It is un- clear whether the United States would have any legal basis for attempting to collect tax in such a case since the individual has lost all rights and ...
Pagina 8
... resident generally is subject to the U.S. individ- ual income tax on his or her worldwide taxable income . All income 1 " Their American Nightmare ; Why Korean Entrepreneurs Are Fleeing Our ... U.S. citizen , whether from sources inside 8.
... resident generally is subject to the U.S. individ- ual income tax on his or her worldwide taxable income . All income 1 " Their American Nightmare ; Why Korean Entrepreneurs Are Fleeing Our ... U.S. citizen , whether from sources inside 8.
Pagina 9
... U.S. citizen or resident earns income from sources outside the United States , and that income is subject to foreign income taxes , the individual generally is permitted a foreign tax credit against his or her U.S. income tax liability ...
... U.S. citizen or resident earns income from sources outside the United States , and that income is subject to foreign income taxes , the individual generally is permitted a foreign tax credit against his or her U.S. income tax liability ...
Pagina 10
A Report. Aliens who physically leave the United States . - Any alien , resident or nonresident , who physically ... U.S. in- come tax obligations . This certificate often is referred to as a “ sail- ing permit " . The certificate may not ...
A Report. Aliens who physically leave the United States . - Any alien , resident or nonresident , who physically ... U.S. in- come tax obligations . This certificate often is referred to as a “ sail- ing permit " . The certificate may not ...
Pagina 11
... U.S. person who expatriates , even for a principal purpose of avoiding U.S. tax , may subsequently engage in ... resident , or by a domestic corporation , partnership , estate or trust , to certain foreign entities in a transaction not ...
... U.S. person who expatriates , even for a principal purpose of avoiding U.S. tax , may subsequently engage in ... resident , or by a domestic corporation , partnership , estate or trust , to certain foreign entities in a transaction not ...
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Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ... Vizualizare completă - 1995 |
Termeni și expresii frecvente
Administration proposal apply basis beneficiary capital gains citizen or resident Congress country of residence deemed sale departure tax distributions double taxation effect estate tax expa expatriating act expatriation tax proposals fair market value foreign tax former citizens gift tax green card Immigration included income tax treaty individual's inheritance tax international law issues Joint Committee staff long-term residents loss of citizenship Macomber marginal tax rates marking to market million modified bills nationality nonresident alien patriation percent on taxable potential present law provisions realization relinquish U.S. citizenship renounce respect retroactive right to emigrate rules section 877 spouse subject to tax subject to U.S. tax avoidance tax haven tax jurisdiction tax on expatriation tax purposes tax rates begin tax treaties taxable transfers taxpayer tion transfers and rise transfers in excess trust interest U.S. citizen U.S. income tax U.S. residents U.S. source income U.S. tax system United
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Pagina 85 - ... international custom, as evidence of a general practice accepted as law; c. the general principles of law recognized by civilized nations ; d. subject to the provisions of Article 59, judicial decisions and the teachings of the most highly qualified publicists of the various nations, as subsidiary...
Pagina 57 - Whereas the right of expatriation is a natural and inherent right of all people, indispensable to the enjoyment of the rights of life, liberty and the pursuit of happiness ; and whereas in the recognition of this principle this government has freely received emigrants from all nations and invested them with the rights of citizenship...
Pagina 86 - Article 2 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. 2. Everyone shall be free to leave any country, including his own.
Pagina 85 - The taxable year in which the property is placed in a condition or state of readiness and availability for a specifically assigned function...
Pagina 77 - As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning...
Pagina 77 - State. 2. As regards the application of the Convention by a Contracting State any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Convention applies. Article 4 RESIDENT 1. For the purposes of this Convention, the term "resident of a Contracting State...
Pagina 30 - 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 67 - Here we have the essential matter: not a gain accruing to capital, not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the capital however invested or employed, and coming in, being 'derived...
Pagina 62 - States and one of whom has had a residence in the United States or one of its outlying possessions, prior to the birth of such person; (d) a person born outside of the United States...
Pagina 57 - SEC. 403. (a) Except as provided in subsections (g) and (h) of section 401, no national can expatriate himself, or be expatriated, under this section while within the United States or any of its outlying possessions, but expatriation shall result from the performance within the United States or any of its outlying possessions of any of the acts or the fulfillment of any of the conditions specified in this section if and when the national thereafter takes up a residence abroad.