Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ReportU.S. Government Printing Office, 1995 |
Din interiorul cărții
Rezultatele 1 - 5 din 51
Pagina ix
... Renounce Citizenship ( As Submit- ted to the Congress on February 6 , 1995 ) Appendix E : Estimating the Revenue Effects of Proposed Legislation to Impose Tax on Expatriation Appendix F : Methodology of Joint Committee on Tax- ation ...
... Renounce Citizenship ( As Submit- ted to the Congress on February 6 , 1995 ) Appendix E : Estimating the Revenue Effects of Proposed Legislation to Impose Tax on Expatriation Appendix F : Methodology of Joint Committee on Tax- ation ...
Pagina 8
... renouncing their citizenship includes naturalized U.S. citizens who return to their countries of birth . For example , accord- ing to the State Department , of the 858 U.S. citizens who relin- quished their citizenship in 1994 , a ...
... renouncing their citizenship includes naturalized U.S. citizens who return to their countries of birth . For example , accord- ing to the State Department , of the 858 U.S. citizens who relin- quished their citizenship in 1994 , a ...
Pagina 9
... renounced U.S. citizenship with a principal purpose of avoiding U.S. taxes ) . The special rule for a break in resi- dency status applies regardless of the subjective intent of the indi- vidual . Aliens who physically leave the United ...
... renounced U.S. citizenship with a principal purpose of avoiding U.S. taxes ) . The special rule for a break in resi- dency status applies regardless of the subjective intent of the indi- vidual . Aliens who physically leave the United ...
Pagina 14
... renounces U.S. nationality before a consular officer , ( 2 ) the date the individual fur- nishes to the State Department a signed statement of voluntary re- linquishment confirming the performance of an expatriating act , ( 3 ) the date ...
... renounces U.S. nationality before a consular officer , ( 2 ) the date the individual fur- nishes to the State Department a signed statement of voluntary re- linquishment confirming the performance of an expatriating act , ( 3 ) the date ...
Pagina 28
... renounced U.S. citizenship with a principal purpose of avoiding U.S. taxes ) . The special rule for a break in residency status applies regardless of the subjective intent of the individual . c . Aliens who physically leave the United ...
... renounced U.S. citizenship with a principal purpose of avoiding U.S. taxes ) . The special rule for a break in residency status applies regardless of the subjective intent of the individual . c . Aliens who physically leave the United ...
Alte ediții - Afișează-le pe toate
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
Pasaje populare
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.