Tax Treatment of Expatriated Citizens: Hearing Before the Committee on Finance, United States Senate, One Hundred Fourth Congress, First Session, on S. 453, S. 700, H.R. 831, H.R. 981, H.R. 1535, and H.R. 1812, July 11, 1995, Volumul 4U.S. Government Printing Office, 1997 - 118 pagini |
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Administration proposal amendment to H.R. apply beneficiary capital gains tax CHAIRMAN citizen or resident citizenship or residence current law determined estate tax exemption expatriate's expatriating act expatriating individual expatriation proposals expatriation tax provisions fair market value foreign corporation gain recognition agreement gift tax green card incentive to expatriate individual's intent interest international law issue JCT Report Joint Committee staff KIES long-term residents loss of citizenship Means Committee bill million modified bills nonresident aliens override pay tax present law principal purpose problem revenue estimates Secretary SAMUELS section 877 Senate amendment Senate bill Senator BRADLEY Senator GRAHAM Senator GRASSLEY Senator Moynihan Senator SIMPSON subject to tax subject to U.S. tax avoidance tax liability tax on expatriation tax on unrealized tax treaties taxable taxpayer transfer Treasury Department treated as U.S. trust U.S. citizens U.S. citizenship U.S. income tax U.S. person U.S. residency U.S. source income United unrealized gains