2012 April # – Dentino

 
William L. Dentino / Christine Manolakas
The exit tax: a move in the right direction
William & Mary Business Law Review 3:2 (Apr 2012) 341-418

http://scholarship.law.wm.edu/wmblr/vol3/iss2/3

[619 footnotes] This article aims to follow “the history and evolution of IR.C. section 877.” Seven sections cover: (1) How the U.S. taxes (2) History of U.S. taxation based on citizenship (3) Foreign Investors Tax Act of 1966 (4) Health Insurance Portability and Accountability Act of 1996 (5) American Jobs Creation Act of 2004 (6) Heroes Earning Assistance and Relief Tax Act of 2008 (7) Continuing Problems. A major conclusion is that “the [current] mark-to-market regime still violates the tax equity objectives of horizontal and vertical equity.”