Add to ORKGThe United States taxes its citizens on their world-wide income. To remove oneself from the U.S. tax system citizens need to expatriate. The Heroes Earnings Assistance and Relief Tax Act of 2008 amended significantly the anti-avoidance provisions of the Internal Revenue Code for an expatriating taxpayer. The new law requires expatriating taxpayers to report a deemed taxable sale and repurchase of assets at the time that they expatriate. This is a change from the prior law where an expatriating taxpayer could be taxed by the U.S. for ten years after expatriation and had a tax avoidance motive. This paper details the new legislation and shows its possible effects
The United States, unlike many sovereignties, has exercised worldwide income tax jurisdiction over i...
Over the years, many OECD countries, including the United States, have identified tax havens as a si...
This Note examines both sides of the coin: the constitutional protections given the individual fight...
The Heroes Earnings Assistance and Relief Tax Act of 2008 amended the anti-avoidance provisions of t...
One possible method of reducing United States income tax liability is to expatriate, or renounce Uni...
In the wake of September 11, 2001, several influential lawmakers have sought to pass tax legislation...
Taxpayers shift income offshore with lawful devices like operating through a foreign corporation. Ta...
Part II of this article provides an overview of the U.S. tax system applicable to citizens, permanen...
Citizenship-based taxation was first enacted during the Civil War, in large part to express congress...
One of the most contentious tax legislative battles of the 104th Congress erupted over the Clinton a...
The Economic Recovery Tax Act of 1981 (ERTA) contains significant provisions liberalizing the taxati...
The author discusses the impact of recent Supreme Court decisions and congressional statutes on the ...
This Note will examine the United States tax treatment of foreign source income, under sections 911 ...
The Tax Increase Prevention and Reconciliation Act of 2005 extended expiring tax-reduction provision...
The Economic Recovery Tax Act of 1981 made major revisions in the taxation of foreign earned income....
The United States, unlike many sovereignties, has exercised worldwide income tax jurisdiction over i...
Over the years, many OECD countries, including the United States, have identified tax havens as a si...
This Note examines both sides of the coin: the constitutional protections given the individual fight...
The Heroes Earnings Assistance and Relief Tax Act of 2008 amended the anti-avoidance provisions of t...
One possible method of reducing United States income tax liability is to expatriate, or renounce Uni...
In the wake of September 11, 2001, several influential lawmakers have sought to pass tax legislation...
Taxpayers shift income offshore with lawful devices like operating through a foreign corporation. Ta...
Part II of this article provides an overview of the U.S. tax system applicable to citizens, permanen...
Citizenship-based taxation was first enacted during the Civil War, in large part to express congress...
One of the most contentious tax legislative battles of the 104th Congress erupted over the Clinton a...
The Economic Recovery Tax Act of 1981 (ERTA) contains significant provisions liberalizing the taxati...
The author discusses the impact of recent Supreme Court decisions and congressional statutes on the ...
This Note will examine the United States tax treatment of foreign source income, under sections 911 ...
The Tax Increase Prevention and Reconciliation Act of 2005 extended expiring tax-reduction provision...
The Economic Recovery Tax Act of 1981 made major revisions in the taxation of foreign earned income....
The United States, unlike many sovereignties, has exercised worldwide income tax jurisdiction over i...
Over the years, many OECD countries, including the United States, have identified tax havens as a si...
This Note examines both sides of the coin: the constitutional protections given the individual fight...