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A. Taxation of United States Citizens, Residents,
and Nonresidents
15
1. Individual income 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 of trusts, estates, and their
beneficiaries
a. Taxation of the trust or estate
c. Grantor trust rules
b. Taxation of distributions to beneficiaries
d. Taxation on disposition of interests in
trusts
e. Residence of trusts
4. Special tax rules with respect to the move-
ment of persons and property into or out
of the United States
26
a. Individuals who relinquish U.S. citizen-
ship with a principal purpose of avoid-
ing U.S. tax
b. Aliens having a break in residency sta-
(V)
sion of issues relating to estimating the revenue effects of proposed
legislation to impose tax on expatriation and current Joint Commit-
tee staff revenue estimates of the expatriation proposals; (F) study
methodology; (G) exchanges of correspondence between the Joint
Committee staff and the Departments of State and Treasury, the
Internal Revenue Service, and the Immigration and Naturalization
Service; and (H) certain State Department information on expatria-
tion for 1994 and 1995.
Over the course of the approximately 2-month period that the
Joint Committee staff prepared this study, the staff reviewed testi-
mony, met extensively with the Administration, legal authorities,
and private practitioners, and consulted at length with individuals
and organizations with an interest in the various proposals to mod-
ify the tax treatment of expatriation. The Joint Committee staff
corresponded with practitioners in other countries that impose tax
on former citizens and residents. The Joint Committee staff met
with economists regarding the potential trade and flow of capital
implications of imposing tax on expatriation. Finally, the Joint
Committee staff did extensive research into the present-law expa-
triation provisions, applicable immigration law, the Privacy Act,
and the legal issues involved in the various proposals to impose tax
on expatriation.
A copy of the draft study was provided to the Treasury Depart-
ment for review and comment.
The Joint Committee staff wishes to thank all those who assisted
in providing data and other information for the study, including
the State Department, the Treasury Department, the Internal Rev-
enue Service, the Immigration and Naturalization Service, the Law
Library of the Library of Congress, and the private tax practition-
ers and economists with experience in expatriation and immigra-
tion issues.
Sincerely,
KENNETH J. KIES,
Chief of Staff.
a. Income taxation of U.S. citizens and resi-
dents
tus
28
c. Aliens who physically leave the United
States
d. Transfers to foreign corporations
B. Requirements for United States Citizenship, Im-
migration, and Visas
1. United States citizenship ....
2. United States immigration and visas
3. Relinquishment of green cards
III. PROPOSALS TO MODIFY TAX TREATMENT OF U.S. CITIZENS
AND RESIDENTS WHO RELINQUISH CITIZENSHIP OR RES-
IDENCE
A. Administration's Fiscal Year 1996 Budget Pro-
posal (H.R. 981 and S. 453)
B. Senate Amendment to H.R. 831
C. Gephardt Proposal
D. Modified Bills Introduced by Senator Moynihan
and Representative Gibbons (S. 700 and H.R.
1535)
42
IV. GENERAL ISSUES RAISED BY THE PROPOSALS
46
A. Scope of the Proposals
B. Date of Loss of Citizenship
50
C. Lifetime Tax Liability Under Present Law and
the Administration Proposal
54
V. SPECIFIC ISSUES RELATING TO PROPOSALS TO MODIFY
THE TAX TREATMENT OF EXPATRIATION
61
A. Effectiveness and Enforceability of Present Law
With Respect to the Tax Treatment of Expatria-
tion
E. Possible Effects on the Free Flow of Capital into
the United States and on the Free Trade Objec-
tives of the United States
101
b. Migration of U.S. citizens and perma-
nent residents
102
c. Migration of non-U.S. citizens
103
d. Potential effects of changes in immigra-
tion on the U.S. economy
104
e. Responsiveness of migration to taxation
f. Cross-border flows of financial and real
105
c. Competent authority relief
113
d. Experience of other countries that im-
pose similar taxes on former citizens
or residents
114
G. Impact of the Proposals on Existing Tax Treaties
and Future Treaty Negotiations
118
1. Problems of applying a mark to market pro-
vision to property interests generally
122
d. Valuation problems arising from mark-
ing-to-market interests in property
127
2. Application of marking to market; interests
in trusts
a. Administration proposal
b. Senate bill and modified bills
c. Technical issues
....
130
132