Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ReportU.S. Government Printing Office, 1995 |
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Pagina 16
... during the second preceding calendar year . Presence for an av- erage of 122 days ( or more ) per year over the three - year period would be sufficient to trigger the test . ties of the countries are to settle the question of 16.
... during the second preceding calendar year . Presence for an av- erage of 122 days ( or more ) per year over the three - year period would be sufficient to trigger the test . ties of the countries are to settle the question of 16.
Pagina 17
A Report. ties of the countries are to settle the question of residence by mu- tual agreement . b . Income taxation of nonresident aliens Non - U.S . citizens who do not meet the definition of " resident aliens " are considered to be ...
A Report. ties of the countries are to settle the question of residence by mu- tual agreement . b . Income taxation of nonresident aliens Non - U.S . citizens who do not meet the definition of " resident aliens " are considered to be ...
Pagina 63
... question on Form 1040NR would enhance enforcement in this area [ and ] must consider whether requiring hundreds of thousands of aliens to respond to a question on Form 1040NR in order to identify a few expatriating taxpayers is an ...
... question on Form 1040NR would enhance enforcement in this area [ and ] must consider whether requiring hundreds of thousands of aliens to respond to a question on Form 1040NR in order to identify a few expatriating taxpayers is an ...
Pagina 69
... question whether it is constitutionally permissible to impose U.S. income tax on the increase in the value of assets that continue to be held by an expa- triate or former long - term resident of the United States . One con- stitutional ...
... question whether it is constitutionally permissible to impose U.S. income tax on the increase in the value of assets that continue to be held by an expa- triate or former long - term resident of the United States . One con- stitutional ...
Pagina 70
... questions , in theory , are dis- tinct , how one views the concept of " realization " is the critical starting point for analyzing both questions . More specifically , the question inevitably must be addressed whether realization is an ...
... questions , in theory , are dis- tinct , how one views the concept of " realization " is the critical starting point for analyzing both questions . More specifically , the question inevitably must be addressed whether realization is an ...
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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.