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 Co. v. C.I.R., 227 F.2d 16, 19-20 (3rd Cir. 1960).) All taxes are known as “indirect taxes,” because they tax an event, rather than an individual or property as such. (Steward Machine Co. v. Davis, 301 U.S. 548, 581-582 (1937).) What turned out 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 a good income tax, that will 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 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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