Taxation of Individulas who Renounce Their U.S. Citizenship: Hearing Before the Committee on Finance, United States Senate, One Hundred Fourth Congress, First Session, March 21, 1995, Band 4
U.S. Government Printing Office, 1995 - 160 Seiten
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accrued Administration aliens American apply appreciation assets avoid basis believe beneficiary bill capital gains Chairman Code Committee Congress considered constitutional corporation Court Covenant customary death deemed Department determined economic effect emigrate enacted event example existing exit tax expatriation fair foreign former gains gift going held holding impose income tax individual interest Internal Revenue Code international law issue Jackson-Vanik Amendment leave legislation long-term resident look March MOYNIHAN nature noted obligations paid period person practice PREPARED STATEMENT present principles prior problem proposal provision question raise realization reasonable received recognized relinquishes renounce reported resident respect restrictions result rules SAMUELS Secretary Section 877 Senator Senator HATCH Soviet statute taxable taxation taxpayer Thank transfer Treasury treaty trust TURNER U.S. citizens U.S. citizenship U.S. tax United Universal
Seite 73 - 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 71 - 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 32 - 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 84 - 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 143 - President determines that such country— (1) denies its citizens the right or opportunity to emigrate; (2) imposes more than a nominal tax on emigration or on the visas or other documents required for emigration, for any purpose or cause whatsoever; or (3) imposes more than a nominal tax, levy, fine, fee, or other charge on any citizen as a consequence of the desire of such citizen to emigrate to the country of his choice...
Seite 66 - 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 16 - 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.
Seite 153 - 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 153 - ... by anticipatory arrangements and contracts however skilfully devised to prevent the salary when paid from vesting even for a second in the man who earned it. That seems to us the import of the statute before us and we think that no distinction can be taken according to the motives leading to the arrangement by which the fruits are attributed to a different tree from that on which they grew.