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Revision as of 23:31, 11 November 2024

The courts have generally held that direct taxes are limited to taxes on people (variously called capitation, poll tax or head tax) and property. (Penn Mutual Indemnity Denver. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) Various other taxes are commonly referred to as "indirect taxes," because they tax an event, rather than an individual or property per se. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What was a straightforward limitation on the power of the legislature based on the subject of the tax proved inexact and unclear when applied with regard to an income tax, that can easily be arguably viewed either as a direct or an indirect tax.

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The second way is to be overseas any 330 days each full twelve month period abroad. These periods can overlap in case of an incomplete year. In this case the filing final target time follows the culmination of each full year abroad.