id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-398	Farkas-DiNardo, Eva	Is the Nation of Immigrants Punishing Its Emigrants: A Critical Review of the Expatriation Rules Revised by the American Jobs Creation Act of 2004	2022	39	.pdf	application/pdf	17452	785	54	The U.S. imposes residence-based taxation on U.S. persons, subjecting them to U.S. income tax on their worldwide income, to U.S. estate tax on their worldwide estates, and to U.S. gift tax on their worldwide gifts. Pursuant to the5 alternative tax regime established by FITA, U.S. citizens who renounced their U.S. citizenship remained subject to U.S. income tax on U.S.-source income, as defined for that purpose, and to U.S. estate and gift tax on transfers of U.S. situs property, for a period of ten years if their expatriation was motivated in part by the avoidance of U.S. taxes.	cache/ftr-398.pdf	txt/ftr-398.txt