Wenzel Jamitzer
Wenzel Jamitzer see Jamnitzer, Wenzel .
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The congressional response to corporate expatriations: the tension between symbols and substance in the taxation of multinational corporations.
Magazine article from: Virginia Tax Review; 1/1/2005; ; 700+ words
; ...3) Instead, expatriation merely reflects a...Recent corporate expatriations have been driven by...address corporate expatriations, (11) and numerous...occurred. (12) The expatriation phenomenon has, in...responses to corporate expatriations, legislators have...
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United States Expatriation Tax Reform
Magazine article from: Beyond Numbers; 11/1/2008; ; 700+ words
; ...gain recognition on the day before expatriation or residency termination. Net gain...liability for the five years preceding expatriation or residency termination exceeds...000,000 or more on the date of expatriation or residency termination; or 3. They...
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Expatriation and the new mark-to-market rules.
Magazine article from: The Tax Adviser; 7/1/2009; ; 700+ words
; ...a deemed sale (on the day before the expatriation takes place) of their worldwide assets...Act of 1966 (3) (FITA) to thwart expatriation as a method of tax avoidance. Upon expatriation, former U.S. citizens or residents...
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New Expatriation Rules Under Sections 877A And 2801.
News Wire article from: Mondaq Business Briefing; 12/2/2008; ; 700+ words
; ...taxes is to expatriate. Under the old expatriation regime, expatriates continued to be...for 10 years after the date of their expatriation. With careful planning, however...day immediately prior to the date of expatriation. The old regime has been entirely...
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The Final State Of Expatriation? - Part 1.
News Wire article from: Mondaq Business Briefing; 9/22/2009; ; 700+ words
; ...the U.S. rules applicable to tax expatriation remained the subject of a continuing...opportunities and perceived abuses arising from expatriation can best be deterred or controlled...foreseeable future, the tax consequences of expatriation by U.S. persons will be governed...
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Successful expatriation and organizational strategies.(managing employees sent abroad)
Magazine article from: Review of Business; 3/22/2002; ; 700+ words
; ...way is through working abroad and "expatriation." An expatriate is an employee who...the question: How can the success of expatriation be improved? We identify three key...improve performance in these areas: 1. Expatriation needs to be tied to the importance...
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Expectations and expatriations: tracing the causes and consequences of corporate inversions.(economic factors associated with corporate expatriations)
Magazine article from: National Tax Journal; 9/1/2002; ; 700+ words
; ...reactions to one announced expatriation, a statistical analysis...analysis of reactions to expatriations--to understand the motivations behind expatriations. As is typical of...analysis of the announced expatriation of Stanley Works is...
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Managing the costs of expatriation: they may be greater than you think.(Fletcher Core)
Magazine article from: Strategic Finance; 5/1/2006; ; 700+ words
; ...in Germany. These desires necessitate the expatriation of management. Expatriation has other advantages, too: Fletcher's...accountants begin to analyze the costs of expatriation, a number of questions evolve. Should Fletcher...
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The Final State Of Expatriation?(Heroes Earning Assistance and Relief Tax Act of 2008)
News Wire article from: Mondaq Business Briefing; 7/23/2008; 700+ words
; ...the U.S. rules applicable to tax expatriation remained the subject of a continuing...opportunities and perceived abuses arising from expatriation can best be deterred or controlled...foreseeable future, the tax consequences of expatriation by U.S. persons will be governed...
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New Expatriation Legislation Passed Unanimously By Congress And Signed By President.
News Wire article from: Mondaq Business Briefing; 6/26/2008; 700+ words
; ...17, 2008 President Bush signed new expatriation legislation unanimously passed by Congress...particularly significant new aspects of the expatriation provisions of the Heroes Act, which...fair market value on the day before expatriation or residency termination. New Code...
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expatriation
Book article from: The Columbia Encyclopedia, Sixth Edition
expatriation loss of nationality . Such loss is...automatically expatriated. In addition, expatriation occurs when a naturalized citizen resides...other countries, forbids voluntary expatriation in time of war. Expatriation may also...
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Expatriation
Dictionary entry from: Dictionary of American History
EXPATRIATION EXPATRIATION is the right of a citizen or subject to transfer allegiance from...possessed this right. Later legislation set conditions under which expatriation would occur, some of which called for loss of citizenship against...
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Trop v. Dulles
Book article from: The Oxford Companion to the Supreme Court of the United States
...contended that Congress could not impose expatriation as punishment without violating the...the Eighth Amendment. Involuntary expatriation, wrote Warren, was cruel and unusual...separately, merely concluded that expatriation for wartime desertion was not a rational...
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Henry James
Encyclopedia entry from: Encyclopedia of World Biography
...the colony of American expatriates James knew in Rome. His Expatriation James's disengagement from America was a long process...Edmond de Goncourt, Émile Zola, and others. His expatriation was complete by the end of that year, when he settled in...
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Miller, Henry
Book article from: The Oxford Companion to American Literature
...a letter about a round‐trip voyage during his expatriation; Max and the White Phagocytes (1938), on one of his unusual...Nexus (1960), is a memoir of his youth and life prior to expatriation in a form partly fictive, partly essay‐like...
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