The Resource Ten years after : a review of developments in relation to Section 911 in the decade following the 2006 amendments

Ten years after : a review of developments in relation to Section 911 in the decade following the 2006 amendments

Label
Ten years after : a review of developments in relation to Section 911 in the decade following the 2006 amendments
Title
Ten years after : a review of developments in relation to Section 911 in the decade following the 2006 amendments
Creator
Subject
Language
eng
Summary
The article deals with the changes under Section 911 introduced by the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA), which was signed into law on 17 May 2006. The changes to Section 911 introduced by TIPRA can be summarized as follows: it accelerated the indexing of the maximum foreign earned income amount; it introduced a new method for calculating the housing cost base amount; it imposed a new, objective cap on the housing amount exclusion of 30% of the foreign earned income amount, subject to upward adjustment for certain foreign locations specified in IRS guidance; it introduced a "stacking rule". The authors of this article address the impact of the TIPRA changes, analyzing in particular how the introduction of the stacking rule would cause Section 911 to be no longer advantageous for U.S. expatriates based in countries with high tax rates relative to those in effect in the United States. This article also analyses how Section 911 has fared in the first post TIPRA decade by surveying the cases and rulings that have addressed issues arising under Section 911 regulation
Citation source
In: Tax management international journal. - Arlington. - Vol. 45 (2016), no. 12 ; 20 p
http://library.link/vocab/creatorName
  • Klasing, M.A
  • Francis, B
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • foreign source income
  • residence
  • foreign earned income exclusion
  • case law
Label
Ten years after : a review of developments in relation to Section 911 in the decade following the 2006 amendments
Instantiates
Publication
Label
Ten years after : a review of developments in relation to Section 911 in the decade following the 2006 amendments
Publication

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