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 Corp. v. C.I.R., lanciao 227 F.2d 16, 19-20 (3rd Cir. 1960).) All other taxes are known as "indirect taxes," within their tax an event, rather than particular or property per se. (Steward Machine Co. v. Davis, 301 U.S. 548, lanciao 581-582 (1937).) What got a straightforward limitation on the power of the legislature based on the subject of the tax proved inexact and unclear when applied to an income tax, that can easily be arguably viewed either as a direct or an indirect tax.

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

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