Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ReportU.S. Government Printing Office, 1995 |
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Pagina 1
... request on behalf of the Administration on February 16 , 1995 ) . The Congress considered a modified version of the Administration proposal , which passed the Senate as an amendment to H.R. 831. H.R. 831 as enacted ( P.L. 104-7 ) did ...
... request on behalf of the Administration on February 16 , 1995 ) . The Congress considered a modified version of the Administration proposal , which passed the Senate as an amendment to H.R. 831. H.R. 831 as enacted ( P.L. 104-7 ) did ...
Pagina 11
... request ) as H.R. 981 by Representatives Gephardt and Gibbons and as S. 453 by Senators Daschle and Moynihan . Among the pro- visions of H.R. 981 and S. 453 was a proposal to modify the tax treatment of U.S. citizens who relinquish ...
... request ) as H.R. 981 by Representatives Gephardt and Gibbons and as S. 453 by Senators Daschle and Moynihan . Among the pro- visions of H.R. 981 and S. 453 was a proposal to modify the tax treatment of U.S. citizens who relinquish ...
Pagina 17
... request that the Internal Revenue Service ( " IRS " ) determine the transferor's maxi- mum tax liability and issue a certificate prescribing a reduced amount of withholding ( not to exceed the transferor's maximum tax liability ) , 14 ...
... request that the Internal Revenue Service ( " IRS " ) determine the transferor's maxi- mum tax liability and issue a certificate prescribing a reduced amount of withholding ( not to exceed the transferor's maximum tax liability ) , 14 ...
Pagina 34
... request a hearing before an immigration judge to have the green card rein- stated . A green - card holder may permanently leave the United States without relinquishing his or her green card , although such individuals would continue to ...
... request a hearing before an immigration judge to have the green card rein- stated . A green - card holder may permanently leave the United States without relinquishing his or her green card , although such individuals would continue to ...
Pagina 35
... request ) in the House ( in H.R. 981 ) and the Senate ( in S. 453 ) on February 16 , 1995. Under the Adminis- tration proposal , U.S. citizens who relinquish their U.S. citizenship and certain long - term resident aliens who terminate ...
... request ) in the House ( in H.R. 981 ) and the Senate ( in S. 453 ) on February 16 , 1995. Under the Adminis- tration proposal , U.S. citizens who relinquish their U.S. citizenship and certain long - term resident aliens who terminate ...
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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.