Definition of a Resident Alien - Proposed Legislative Changes

Article Abstract:

Since Omnibus tax legislation was defeated, there is still no resolution as to the definition of resident aliens for Internal Revenue Service (IRS) purposes. Congress devoted a good deal of concern to this point in their sessions on international tax policy. Resident alien and nonresident alien have no specific definition. A subjective test as to intentions to stay in the United States has been used. H.R. 4170, Section 451 is intended to furnish an objective sense of resident alien designations, as well as raise revenue. Consensus exists as to the need of such an objective definition, but disagreement exists as to the styling of the definition. Consensus exists as to exclusion from residence status for diplomats, academics (not as to tax), and trainees. Considerations of residency for one year are based on lawful and permanent residence in the United States during the year, physical presence for sixty days with a pending immigrant visa and substantial presence tests for three years. Green card obtainment's effect on residency is defined.

Laws, regulations and rules, Economic policy, United States. Congress, United States. Internal Revenue Service, Citizenship

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Trends: Switzerland

Article Abstract:

Zurich's tax laws were altered in 1983 with new regulations for dividend income and administrative firms. The federal notion of dividend income is defined through a comparison of formal requirements. Of significant importance is the notion that the federal holding privilege will not encure to capital gains. Capital gains are treated with progressive federal income tax rates. No special tax status for domiciliary and mixed-domiciliary firms is accorded. Service company status is recognized. The Zurich canton has developed two tests for dividend income apart from the federal interpretation. The new rules allow exemptions according to the seventy-five per cent test and partial exemptions for progressive taxation. The Zurich canton uses the net income method in contrast to the gross income method used by the federation. Administrative operations are chiefly defined as being other than trading operations.

Taxation, Switzerland, Commerce

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