Issues Presented by Proposals to Modify the Tax Treatment of Expatriation: A ReportU.S. Government Printing Office, 1995 |
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Administration proposal Appendix Table apply assets basis beneficiary BIRTH DATE LOSS capital gains certificate of loss citizen or resident competent authority Congress country of residence DATE LOSS DATE deemed sale departure tax double taxation drilling rig effect estate tax exempt expa expatriating act expatriation tax proposals foreign tax former citizens gift tax grantor green card individual's inheritance tax Internal Revenue Internal Revenue Service international law Joint Committee staff long-term residents loss of citizenship Loss of Nationality marginal tax rates marking to market million nonresident alien percent on taxable present law provisions realization relinquish U.S. citizenship renounce renunciation respect retroactive right to emigrate rules section 877 spouse subject to tax subject to U.S. tax avoidance tax jurisdiction tax on expatriation tax purposes tax rates begin tax treaties taxable transfers taxpayer tion transfers in excess U.S. citizen U.S. income tax U.S. resident United