Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ReportU.S. Government Printing Office, 1995 |
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Pagina 60
... realization the Administration proposal may increase the lifetime tax liability of the expatriate . Similarly , if the assets were to decline in value sub- sequent to expatriation , the lifetime tax liability imposed by the ...
... realization the Administration proposal may increase the lifetime tax liability of the expatriate . Similarly , if the assets were to decline in value sub- sequent to expatriation , the lifetime tax liability imposed by the ...
Pagina 69
... realization of gain ( to the extent such gain exceeds $ 600,000 if one individual expatriates or $ 1.2 million if both hus- band and wife expatriate ) that would be subject to U.S. income tax . Similarly , S. 700 and H.R. 1535 also ...
... realization of gain ( to the extent such gain exceeds $ 600,000 if one individual expatriates or $ 1.2 million if both hus- band and wife expatriate ) that would be subject to U.S. income tax . Similarly , S. 700 and H.R. 1535 also ...
Pagina 70
... realization , there is nothing that can be subject to tax ) or , rather , is realization a concept for deter- mining the timing for when a tax liability will be finalized ( such that increases in the value of assets are encompassed in ...
... realization , there is nothing that can be subject to tax ) or , rather , is realization a concept for deter- mining the timing for when a tax liability will be finalized ( such that increases in the value of assets are encompassed in ...
Pagina 71
... realization " usually begins by addressing the issue of the continued validity and scope of the U.S. Supreme Court's decision in Eisner v . Macomber , 252 U.S. 189 ( 1920 ) . This has been a topic of debate for 75 years . 129 The ...
... realization " usually begins by addressing the issue of the continued validity and scope of the U.S. Supreme Court's decision in Eisner v . Macomber , 252 U.S. 189 ( 1920 ) . This has been a topic of debate for 75 years . 129 The ...
Pagina 72
... realization event requirement of the Macomber ruling continues to have some vitality as a matter of constitutional law , the question follows whether the expatriation tax proposals nonetheless pass constitutional muster on the ground ...
... realization event requirement of the Macomber ruling continues to have some vitality as a matter of constitutional law , the question follows whether the expatriation tax proposals nonetheless pass constitutional muster on the ground ...
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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.