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In specific cases, the tax system may diverge for different categories of individuals. U.S. citizen and resident alien decedents are subject to estate tax on all of their assets, wherever situated. The nonresident aliens are subject to estate tax only on that part of the gross estate which at the time of death is situated in the U.S.
Residents taxpayers are taxed on their worldwide income. Non-residents taxpayers are taxed on their income derived from Dutch sources. There are two sorts of double taxation relief in The Netherlands. Economic double taxation relief is available with regard to proceeds from substantial equity investments under the participation.
The Substantial Presence Test (SPT) is a criterion used by the Internal Revenue Service (IRS) in the United States to determine whether an individual who is not a citizen or lawful permanent resident in the recent past qualifies as a "resident for tax purposes" or a "nonresident for tax purposes"; [1] [2] it is a form of physical presence test.
An expatriation tax or emigration tax is a tax on persons who cease to be tax-resident in a country. This often takes the form of a capital gains tax against unrealised gain attributable to the period in which the taxpayer was a tax resident of the country in question.
Domiciled individuals are subject to French tax on worldwide income, but non-residents are not taxed on foreign-source income. Many treaty exemptions may apply, however (e.g. foreign-source trading or rental income). Under Article 4B of the French Tax Code (Code Général des Impôts), an individual is resident in France for tax purposes if:
In addition, the bona fide residence test takes into account factors such as the individual's intention, the purpose of the trip, and the length and nature of the stay. There are special deductions and exclusions that accompany this only if the individual is a U.S. citizen or U.S. resident alien and has a tax treaty.
Individual taxpayers can be classified as either a citizen or an alien (an alien is a person who resides within the borders of a country and is not a national of that country). A citizen can further be classified as either a resident citizen or a non-resident citizen. Corporations can be classified into domestic, foreign and partnership.
The Green Card Test (GCT) is a criterion used by the Internal Revenue Service (IRS) in the United States to determine whether an individual qualifies as a "resident for tax purposes". The GCT asks whether, during the calendar year , an individual spent at least one day in the US as a lawful permanent resident (i.e. possessed a green card).