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The courts have generally held that direct taxes are restricted to taxes on people (variously called capitation, poll tax or head tax) and property. (Penn Mutual Indemnity Company. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) Any other taxes are typically called "indirect taxes," as these tax an event, rather than person or property as such. (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 topic of the tax proved inexact and unclear when applied for income tax, that will be arguably viewed either as a direct or an indirect tax.

Julie's total exclusion is $94,079. In her American expat tax return she also gets declare a personal exemption ($3,650) and standard deduction ($5,700). Thus, her taxable income is negative. She owes no U.S. place a burden on.

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