Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ReportU.S. Government Printing Office, 1995 |
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Pagina i
... taxation 15 a . Income taxation of U.S. citizens and resi- dents b . Income taxation of nonresident aliens ..... 2. Estate and gift taxation a . In general b . Gift tax c . Estate tax d . Generation - skipping transfer tax 3. Income ...
... taxation 15 a . Income taxation of U.S. citizens and resi- dents b . Income taxation of nonresident aliens ..... 2. Estate and gift taxation a . In general b . Gift tax c . Estate tax d . Generation - skipping transfer tax 3. Income ...
Pagina v
... taxation a . Income taxation of U.S. citizens and resi- dents b . Income taxation of nonresident aliens 2. Estate and gift taxation a . In general b . Gift tax ..... c . Estate tax d . Generation - skipping transfer tax 3. Income taxation ...
... taxation a . Income taxation of U.S. citizens and resi- dents b . Income taxation of nonresident aliens 2. Estate and gift taxation a . In general b . Gift tax ..... c . Estate tax d . Generation - skipping transfer tax 3. Income taxation ...
Pagina viii
... transfers 142 b . Foreign to foreign transfers 143 2. Enhance coordination between the State De- partment and the IRS 143 3. Enhance compliance by U.S. citizens and green - card holders residing outside the United States 143 APPENDICES ...
... transfers 142 b . Foreign to foreign transfers 143 2. Enhance coordination between the State De- partment and the IRS 143 3. Enhance compliance by U.S. citizens and green - card holders residing outside the United States 143 APPENDICES ...
Pagina 10
... tax will not be jeopardized by the departure of the alien . Transfers to foreign corporations . - Certain transfers of prop- erty by shareholders to a controlled corporation are generally tax- free if the persons transferring the ...
... tax will not be jeopardized by the departure of the alien . Transfers to foreign corporations . - Certain transfers of prop- erty by shareholders to a controlled corporation are generally tax- free if the persons transferring the ...
Pagina 13
... taxable years . ( 2 ) A nonresident alien individual who becomes a citizen ... taxable years before the date of relinquishment . ( 6 ) The bills would provide ... transferred by an individ- ual who relinquished his U.S. citizenship with a ...
... taxable years . ( 2 ) A nonresident alien individual who becomes a citizen ... taxable years before the date of relinquishment . ( 6 ) The bills would provide ... transferred by an individ- ual who relinquished his U.S. citizenship with a ...
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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.