On Sun, 28 Apr 1996, E. ALLEN SMITH wrote:
Of course, the mainstream media is failing to question why such taxes should be in existence at all. -Allen
Billionaires' tax loophole could complicate passage of health reform --------------------------------------------------------------------------- Copyright 1996 Nando.net Copyright 1996 The Associated Press
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Instead of imposing a large and immediate tax on wealthy citizenship renouncers, the House version tightens current law. It requires expatriates with a net worth of $500,000 or more to pay taxes on capital gains and other income from U.S.-based assets for 10 years after they renounce their citizenship.
Uh. Hmmmmm. I refer you to section 877 of the current tax law. (a) In General.- Every nonresident alien individual who at any time after March 8, 1965, and within the 10 year period immediately preceding the close of the taxible year lost United States citizenship [unless he shows non-tax avoidance intent with the burden on taxpayer to make such showing] shall be taxable for such taxable year in the manner provided in subsection (b)... (b) Alternate Tax: [Imposes the larger of normal taxation calculation and the calculation with the source rules in (c)]. (c) Special Rules of Source.- For purposes of subsection (b), the following items of gross income shall be treated as income from sources within the United States: [Sale of real property or stocks and debt obligations] (end) In other words, you get taxed on capital gains and sale of stock or property as well as real income for 10 years after your expatriation if you cannot show you renounced citizenship for non-tax purposes. What precisely does this reporter think is being "tightened" in his or her version of the House bill? (Note that in current law there is no $500,000 floor). In fact the reporter hasn't bothered to describe what the provision really does. (Imposes a expatriation is taxable event analysis). Talk about a snow job. I won't say it is or is not advertant, but it's bloody annoying.
The House version would be extremely difficult to enforce and would allow patient expatriates to avoid the tax by holding their assets for 10 years before selling, they say. In the interim, they could raise cash by borrowing against the assets.
Which is the law today. What is with this guy? Get your facts straight media. --- My preferred and soon to be permanent e-mail address:unicorn@schloss.li "In fact, had Bancroft not existed, potestas scientiae in usu est Franklin might have had to invent him." in nihilum nil posse reverti 00B9289C28DC0E55 E16D5378B81E1C96 - Finger for Current Key Information Opp. Counsel: For all your expert testimony needs: jimbell@pacifier.com