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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).) All other taxes are typically called "indirect taxes," as these tax an event, rather than particular or property as such. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What seemed to be a straightforward limitation on the power of the legislature based on the main topic of the tax proved inexact and unclear when applied for income tax, which could be arguably viewed either as a direct or an indirect tax.

Julie's total exclusion is $94,079. To be with 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. irs.

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