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 11.
99. lappuse
... tax consequences from all potential tax juris- dictions ) from the decision to retain or renounce U.S. citizenship may be neutralized in the case where a person is considering relocating to a tax - haven country ; but this would not be ...
... tax consequences from all potential tax juris- dictions ) from the decision to retain or renounce U.S. citizenship may be neutralized in the case where a person is considering relocating to a tax - haven country ; but this would not be ...
100. lappuse
... tax evasion which could result under present law when persons renounce U.S. citizenship and move to a so - called " tax haven . " See Norr , supra , 17 Tax L. Rev. at 458-59 ( refer- ring to enactment of CFC rules in 1962 : " [ T ] he ...
... tax evasion which could result under present law when persons renounce U.S. citizenship and move to a so - called " tax haven . " See Norr , supra , 17 Tax L. Rev. at 458-59 ( refer- ring to enactment of CFC rules in 1962 : " [ T ] he ...
103. lappuse
... tax haven countries prior to immigrating to the United States . This suggests that the Administration proposal , S. 700 , and H.R. 1535 210 Under present - law section 877 , an expatriate may be liable for certain taxes for up to 10 ...
... tax haven countries prior to immigrating to the United States . This suggests that the Administration proposal , S. 700 , and H.R. 1535 210 Under present - law section 877 , an expatriate may be liable for certain taxes for up to 10 ...
107. lappuse
... tax havens would not alter this result . Most tax havens are small countries not suitable for substantial eco- nomic development . As such , real resources will flow to the same investments in the same countries as if the tax haven did ...
... tax havens would not alter this result . Most tax havens are small countries not suitable for substantial eco- nomic development . As such , real resources will flow to the same investments in the same countries as if the tax haven did ...
110. lappuse
... tax - haven jurisdiction with no income tax , or ( 2 ) the individual becomes a resident in a country with an income tax system that excludes capital gains from its tax base.233 The discussion that follows addresses the issue of double ...
... tax - haven jurisdiction with no income tax , or ( 2 ) the individual becomes a resident in a country with an income tax system that excludes capital gains from its tax base.233 The discussion that follows addresses the issue of double ...
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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.