Taxation of Individuals who Renounce Their U.S. Citizenship: Hearing Before the Committee on Finance, United States Senate, One Hundred Fourth Congress, First Session, March 21, 1995U.S. Government Printing Office, 1996 - 160 Seiten |
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Administration's proposal American apply appreciation assets basis Bob Packwood BOREK capital gains Chairman citizen who relinquishes Committee on Finance CONGRE CONGRESS THE LIBRARY Covenant on Civil customary international law deemed sale enacted estate tax exit tax fair market value foreign corporation foreign person gift tax human rights law impose income beneficiary individual interest Internal Revenue international human rights issue Jackson-Vanik Amendment Langer LIBRARY OF CONGRESS long-term resident March 95 mark to market nationality PREPARED STATEMENT provision realization remainderman renunciation renunciation of citizenship resident aliens right to emigrate right to leave ROBERT F rules Secretary SAMUELS Section 201 Section 877 Senator HATCH Senator MOYNIHAN STATEMENT OF PROF subject to U.S. tax avoidance tax law tax liability tax on expatriation tax policy tax resident tax treaties taxpayer TURNER 21 March U.S. citizens U.S. citizenship U.S. income tax U.S. person U.S. real property U.S. tax U.S.-source United
Beliebte Passagen
Seite 77 - All members pledge themselves to take joint and separate action in cooperation with the organization for the achievement of the purposes set forth in Article 55.
Seite 31 - No one shall be arbitrarily deprived of his nationality nor denied the right to change his nationality.
Seite 75 - 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...
Seite 70 - When, in the course of human events, it becomes necessary for one people to dissolve the political bands which have connected them with another, and to assume among the powers of the earth, the separate and equal station to which the laws of nature and of nature's God entitle them, a decent respect for the opinions of mankind requires, that they should declare the causes which impel them to the separation.
Seite 88 - As home his footsteps he hath turned, From wandering on a foreign strand ? If such there breathe, go mark him well ; For him no minstrel raptures swell ; High though his titles, proud his name, Boundless his wealth as wish can claim ; Despite those titles, power, and pelf, The wretch concentered all in self, Living, shall forfeit fair renown, And, doubly dying, shall go down To the vile dust from whence he sprung, Unwept, unhonored, and unsung.
Seite 149 - The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money) received.
Seite 151 - the gain derived from capital,' etc. 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...
Seite 36 - American citizens, with their descendants, are subjects of foreign states, owing allegiance to the governments thereof; and whereas it is necessary to the maintenance of public peace that this claim of foreign allegiance should be promptly and finally disavowed...
Seite 157 - Net income" means the gross income computed under section 22, less the deductions allowed by section 23. SEC. 22. GROSS INCOME. (a) GENERAL DEFINITION. — "Gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid...
Seite 20 - Everyone shall be free to leave any country, including his own. 3 The above-mentioned rights shall not be subject to any restrictions except those which are provided by law, are necessary to protect national security, public order (ordre public), public health or morals or the rights and freedoms of others, and are consistent with the other rights recognized in the present Covenant.