Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A Report |
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248 See testimony of Stephen E. Shay before the Subcommittee on Oversight of the House Committee on Ways and Means , March 27 , 1995 . 249 See Appendix B for a comparison of the different regimes . ones currently proposed .
248 See testimony of Stephen E. Shay before the Subcommittee on Oversight of the House Committee on Ways and Means , March 27 , 1995 . 249 See Appendix B for a comparison of the different regimes . ones currently proposed .
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Administration proposal apply basis beneficiary capital gains citizen or resident Congress country of residence deemed sale departure tax 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 nonresident alien percent on taxable potential present law provisions realization relinquish U.S. citizenship renounce resi 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 Treasury Department trust interest U.S. citizen U.S. income tax U.S. resident U.S. source income U.S. tax system United
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