Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ReportU.S. Government Printing Office, 1995 |
No grāmatas satura
1.–5. rezultāts no 100.
1. lappuse
... assets of U.S. citizens who expatriate for tax avoidance purposes . The Joint Committee staff has identified certain problems with the present - law provisions , in- cluding the following : • There are legal methods to avoid some or all ...
... assets of U.S. citizens who expatriate for tax avoidance purposes . The Joint Committee staff has identified certain problems with the present - law provisions , in- cluding the following : • There are legal methods to avoid some or all ...
2. lappuse
... assets and careful tax planning can be used to relocate assets outside the United States and , therefore , outside the scope of section 877 . The Administration believes that section 877 is unadministrable because it is difficult to ...
... assets and careful tax planning can be used to relocate assets outside the United States and , therefore , outside the scope of section 877 . The Administration believes that section 877 is unadministrable because it is difficult to ...
3. lappuse
... assets notwithstanding the fact that the beneficiary has no access to the trust assets . This particular aspect of the proposal raises potential constitutional issues at least under certain circumstances . Moreover , under certain cir ...
... assets notwithstanding the fact that the beneficiary has no access to the trust assets . This particular aspect of the proposal raises potential constitutional issues at least under certain circumstances . Moreover , under certain cir ...
4. lappuse
... assets is stepped up to the fair market value of the assets on the date of the decedent's death , and thus there would be little or no expatriation tax imposed on such as- sets . A similar incentive would exist for those who have re ...
... assets is stepped up to the fair market value of the assets on the date of the decedent's death , and thus there would be little or no expatriation tax imposed on such as- sets . A similar incentive would exist for those who have re ...
5. lappuse
... assets in reliance upon present law ? • Does the proposal impose a tax that is fair in relation to its goals ? Is the tax imposed consistent with the U.S. normative system of taxation or is it an extraordinary tax ? If it is an ex ...
... assets in reliance upon present law ? • Does the proposal impose a tax that is fair in relation to its goals ? Is the tax imposed consistent with the U.S. normative system of taxation or is it an extraordinary tax ? If it is an ex ...
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Bieži izmantoti vārdi un frāzes
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
Populāri fragmenti
85. lappuse - ... 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...
57. lappuse - 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...
86. lappuse - 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.
85. lappuse - The taxable year in which the property is placed in a condition or state of readiness and availability for a specifically assigned function...
77. lappuse - 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...
77. lappuse - 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...
30. lappuse - 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...
67. lappuse - 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...
62. lappuse - 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...
57. lappuse - 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.