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 Denver. v. C.I.R., 227 F.2d 16, xnxx 19-20 (3rd Cir. 1960).) All other taxes are typically called “indirect taxes,” because they tax an event, rather than person or property by itself. (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 topic of the tax proved inexact and unclear when applied to an income tax, that arguably viewed either as a direct or an indirect tax.
Julie’s total exclusion is $94,079. On 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. charge. 
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