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 53.
viii. lappuse
... Section 877 138 138 1. Apply section 877 without regard to intent 2. Expand sections 877 , 2107 , and 2501 ( a ) ( 3 ) to tax certain expatriates who leave and maintain a presence in the United States ... B. Suggestions to Modify the ...
... Section 877 138 138 1. Apply section 877 without regard to intent 2. Expand sections 877 , 2107 , and 2501 ( a ) ( 3 ) to tax certain expatriates who leave and maintain a presence in the United States ... B. Suggestions to Modify the ...
1. lappuse
... Code section 877 imposes U.S. income tax on the U.S. 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 ...
... Code section 877 imposes U.S. income tax on the U.S. 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 ...
2. lappuse
... Section 877 only applies to U.S. - source 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 ...
... Section 877 only applies to U.S. - source 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 ...
4. lappuse
... section 877 should be modified , there are alternatives to the Administration pro- posal that may be more appropriate . In evaluating such alter- natives , the following issues should be considered : • What is the underlying rationale ...
... section 877 should be modified , there are alternatives to the Administration pro- posal that may be more appropriate . In evaluating such alter- natives , the following issues should be considered : • What is the underlying rationale ...
9. lappuse
... Section 877 does not apply to resident aliens who terminate their U.S. residency . The alternative method of taxation under section 877 modifies the rules generally applicable to the taxation of nonresident aliens in two ways . First ...
... Section 877 does not apply to resident aliens who terminate their U.S. residency . The alternative method of taxation under section 877 modifies the rules generally applicable to the taxation of nonresident aliens in two ways . First ...
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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.