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Example: Mary, an American citizen, is single and lives in Bermuda. She earns transfer pricing an income of $450,000. Part of Mary's income will be subject to U.S. tax at the 39.6% tax rate.

Congress finally acted on New Year's Day, passing the "fiscal cliff" rule. This law extended the existing tax rate structure for single taxpayers with taxable income of as compared to USD 400,000, and married taxpayers with taxable income of less than USD 450,000. For having higher incomes, the top tax rate was increased to 40.6% These limits are determined before the foreign earned income exception to this rule.

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