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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Termeni și expresii frecvente
Administration proposal Administration's amendment to H.R. apply avoid U.S. tax beneficiary capital gains Chairman citizen or resident citizenship or residence CONGRESS THE LIBRARY current law determined estate tax expatriate's expatriating act expatriating individual expatriation proposals expatriation tax provisions fair market value foreign corporation gain recognition agreement gift tax green card individual's interest international law issue JCT Report Joint Committee staff KIES LIBRARY OF CONGRESS long-term residents loss of citizenship Means Committee bill million modified bills nonresident aliens override present law principal purpose RARY relinquished citizenship RESS revenue estimates Secretary SAMUELS section 877 Senate amendment Senate bill Senator BRADLEY Senator GRAHAM Senator Moynihan 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
Pasaje populare
Pagina 111 - In the exercise of his rights and freedoms, everyone shall be subject only to such limitations as are determined by law solely for the purposes of securing due recognition and respect for the rights and freedoms of others and of meeting the just requirements of morality, public order and the general welfare in a democratic society.
Pagina 111 - Everyone has the right to freedom of movement and residence within the borders of each state. 2. Everyone has the right to leave any country, including his own, and to return to his country.
Pagina 111 - No one shall be imprisoned merely on the ground of inability to fulfil a contractual obligation. Article 12. 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.
Pagina 74 - Extensive hearings followed before the House Committee on Ways and Means, and the Senate Committee on Finance.
Pagina 112 - The above-mentioned rights shall not be subject to any restrictions except those which are provided by law, are necessary to protect national security, public order (ordre public), public health or morals or the rights and freedoms of others, and are consistent with the other rights recognized in the present Covenant.
Pagina 40 - There is hereby imposed for each taxable year a tax of 30 percent of the amount received from sources within the United States by a foreign corporation as — "(1) interest, dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, and other fixed or determinable annual or periodical gains, profits, and income...
Pagina 49 - 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 40 - ... he shall be deemed to be a resident of the country in which he has an habitual abode. If the individual has an habitual abode in both countries or in neither of them, he shall be deemed to be a resident of the country of which he is a citizen. If each country considers...
Pagina 107 - No one shall be arbitrarily deprived of his nationality nor denied the right to change his nationality.
Pagina 110 - Everyone has the right to the protection of the law against such interference or attacks. Article 13. 1. Everyone has the right to freedom of movement and residence within the borders of each state.