 | United States. Congress. House. Committee on Ways and Means - 1967 - 1068 lapas
...the expatriate must carry the burden of proving that the loss of citizenship did not have, for one of its principal purposes, the avoidance of US income, estate, or gift taxes. However, the new section excepts persons whose loss of citizenship occurs under circumstances where... | |
 | United States. Congress. Internal Revenue Taxation Joint Committee - 1967 - 66 lapas
...the expatriate must carry the burden of proving that the loss of citizenship did not have, for one of its principal purposes, the avoidance of US income, estate, or gift taxes. However, the new section cxcepts persons whose loss of citizenship occurs under circumstances where... | |
 | United States. Congress. House. Committee on Ways and Means - 1967 - 1204 lapas
...within the 10-year period ending with the date of transfer if such loss of US citizenship had for one of its principal purposes the avoidance of US income, estate, or gift tax. Accordingly, in the case of such an expatriate, the tax provided in section 2502 is imposed on... | |
 | United States. Internal Revenue Service - 1979 - 644 lapas
...into effect. The proposed protocol provides that for this purpose the term "citizen" includes a former citizen whose loss of citizenship had as one of its principal purposes the avoidance of income tax. Treatment as a US citizen will continue for a period of 10 years following... | |
 | United States. Tax Court - 1985 - 1036 lapas
...present Convention had not come into effect. For this purpose the term "citizen" shall include a former citizen whose loss of citizenship had as one of its principal purposes the avoidance of income tax, but only for a period of 10 years following such loss." Respondent contends,... | |
 | United States. Tax Court - 1986 - 1142 lapas
...Article IV (Residence)) and, in the case of the United States, its citizens (including a former citizens whose loss of citizenship had as one of its principal purposes the avoidance of tax, but only for a period of more specific language implies that section 877 does not... | |
 | United States. Congress. Joint Committee on Taxation - 1979 - 26 lapas
...into effect. The proposed protocol provides that for this purpose the term "citizen" includes a former citizen whose loss of citizenship had as one of its principal purposes the avoidance of income tax. Treatment as a US citizen will continue for a period of 10 years following... | |
 | United States. Congress. Joint Committee on Taxation - 1979 - 1376 lapas
...into effect. The proposed protocol provides that for this purpose the term "citizen" includes a former citizen whose loss of citizenship had as one of its principal purposes the avoidance of income tax. Treatment as a US citizen will continue for a period of 10 years following... | |
 | United States. Congress. Joint Committee on Taxation - 1981 - 38 lapas
...other entities as well as individuals (Article 4. Fiscal Residence) . Under section 877,1 a former citizen whose loss of citizenship had as one of its principal purposes the avoidance of US income tax, will, in certain cases, be subject to tax for a period of ten years following the loss of citizenship.... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 lapas
...provision, similar to the US Model, explicitly covering former citizens in the saving clause. Thus, a former US citizen whose loss of citizenship had as one of its principal purposes the avoidance of income tax will continue to be subject to US income tax, in accordance with the provisions... | |
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citizen" shall include a former citizen whose loss of citizenship had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss. 
