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 bill Bob Packwood BOREK capital gains Chairman citizen who relinquishes Congress customary international law deemed sale enacted estate tax exit tax fair market value foreign corporation foreign person gift tax grantor trust human rights law immigration impose income tax treaties individual Internal Revenue international human rights issue Jackson-Vanik Amendment long-term residents March 95 mark to market nationality PREPARED STATEMENT present law provision realized relinquished his citizenship relinquishes citizenship remainderman renunciation renunciation of citizenship right to emigrate right to leave ROBERT F rules Secretary SAMUELS Section 201 Section 877 Senator HATCH Senator MOYNIHAN Soviet STATEMENT OF PROF subject to U.S. tax avoidance tax law tax liability tax on expatriation tax policy tax purposes tax resident tax treaties taxpayer TURNER 21 March U.S. citizens U.S. citizenship U.S. income tax U.S. persons U.S. real property U.S. source United