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.
vi. lappuse
... 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 ...
... 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 ...
viii. lappuse
... loss date with the Immigration and Nationality Act 140 2. Narrow the scope of the proposals 140 3. Adopt an income tax approach 141 4. Exclude assets that produce foreign source income 141 5. Modify the treatment of trust interests 141 ...
... loss date with the Immigration and Nationality Act 140 2. Narrow the scope of the proposals 140 3. Adopt an income tax approach 141 4. Exclude assets that produce foreign source income 141 5. Modify the treatment of trust interests 141 ...
ix. lappuse
... Loss of Citi- zenship ) if Such Loss Had as One of Its Principal Purposes the Avoidance of Tax Appendix Table A - 3. - Treaties that Contain Savings Clauses That Expressly Apply to Current and Former Citizens After the Loss of ...
... Loss of Citi- zenship ) if Such Loss Had as One of Its Principal Purposes the Avoidance of Tax Appendix Table A - 3. - Treaties that Contain Savings Clauses That Expressly Apply to Current and Former Citizens After the Loss of ...
3. lappuse
... loss with the U.S. government through acquisition of a certificate of loss of nationality from the Department of State of the United States ( " State Department " ) . If such an individual were to apply for a certificate of loss of ...
... loss with the U.S. government through acquisition of a certificate of loss of nationality from the Department of State of the United States ( " State Department " ) . If such an individual were to apply for a certificate of loss of ...
9. lappuse
... loss of U.S. citizenship would , but for the ap- plication of this provision , result in a substantial reduction in U.S. tax based on the expatriate's probable income for the taxable year , then the expatriate has the burden of proving ...
... loss of U.S. citizenship would , but for the ap- plication of this provision , result in a substantial reduction in U.S. tax based on the expatriate's probable income for the taxable year , then the expatriate has the burden of proving ...
Citi izdevumi - Skatīt visu
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.