How To Integrate Company And Shareholder Taxation

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How To Integrate Company And Shareholder Taxation

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Author : Matt Benge
language : en
Publisher:
Release Date : 1986

How To Integrate Company And Shareholder Taxation written by Matt Benge and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1986 with Corporations categories.

The Taxation Of Corporations And Shareholders

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Author : Martin Norr
language : en
Publisher: Springer Science & Business Media
Release Date : 2013-06-29

The Taxation Of Corporations And Shareholders written by Martin Norr and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-06-29 with Business & Economics categories.

This monograph is principally the work of the late Martin Norr. He completed a draft of the entire monograph but had not yet revised it when he died in late 1972. At that time, the integration of corporate and shareholder taxation was just beginning to become of widespread interest in the United States. With the increasing interest thereafter, the International Tax Program began to revise his manuscript, making as few changes as possible in the original draft. We had the benefit of criticism and analysis from Professor Richard M. Bird of the University of Toronto, now Director of the Institute of Policy Analysis there. In addition, Mr. Mitsuo Sato of the Ministry of Finance in Japan gave freely of his time in carefully suggesting changes throughout the manuscript. The present version of Chapter 3 owes a great deal to his additions and suggestions. Thanks are also due to Professor Hugh J. Ault of Boston College Law School for the Appendix, containing his description of the German integration system that became effective in 1977, which was first published in Law & Policy in International Business. Mr. Norr's interest in the subject of corporate and shareholder taxation developed while he was writing the International Tax Program's World Tax Series volume Taxation in France, published in 1966. The integration of French taxes on corporations and shareholders took place just after that volume was finished, but had been under discussion in France for some time before then.

Possible Implications Of Integrating The Corporate And Individual Income Taxes In The United States

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Author : International Monetary Fund
language : en
Publisher: International Monetary Fund
Release Date : 1990-07-01

Possible Implications Of Integrating The Corporate And Individual Income Taxes In The United States written by International Monetary Fund and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 1990-07-01 with Business & Economics categories.

The classical corporate profits tax in the United States involves non-neutralities between: different sources of financing; different forms of business organization; and retaining or distributing earnings and may result in the U.S. investor being at a disadvantage vis-à-vis foreign investors. An international comparison is provided, and the potential effects of different integration schemes on the user cost of capital and tax revenues are assessed. The integration of corporate and individual income taxes in the United States could lead to a more efficient domestic and worldwide allocation of resources.

Integration Of The Corporate And Shareholder Tax Systems

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Author : American Institute of Certified Public Accountants. Tax Division
language : en
Publisher:
Release Date : 1993

Integration Of The Corporate And Shareholder Tax Systems written by American Institute of Certified Public Accountants. Tax Division and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1993 with Corporations categories.

International Aspects Of Corporate Shareholder Tax Integration

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Author : George N. Carlson
language : en
Publisher:
Release Date : 1980

International Aspects Of Corporate Shareholder Tax Integration written by George N. Carlson and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1980 with Corporations categories.

The Integration Of Corporate And Personal Taxes In Europe

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Author : Michael P. Devereux
language : en
Publisher: The Committee
Release Date : 1997

The Integration Of Corporate And Personal Taxes In Europe written by Michael P. Devereux and has been published by The Committee this book supported file pdf, txt, epub, kindle and other format this book has been release on 1997 with Business tax categories.

The paper describes in some detail the imputation systems in France, Germany, Italy and the United Kingdom, paying particular attention to the minimum tax. It also briefly addresses a number of economic issues; it examines the likely impact of the minimum tax on the investment and financing decisions of companies, and outlines how the impact of the imputation system depends on the minimum tax; and it also briefly raises the issue of alternative forms of taxation of corporate source income.

Report Of The Department Of The Treasury On Integration Of The Individual And Corporate Tax Systems

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Author : United States. Department of the Treasury
language : en
Publisher: Department
Release Date : 1992

Report Of The Department Of The Treasury On Integration Of The Individual And Corporate Tax Systems written by United States. Department of the Treasury and has been published by Department this book supported file pdf, txt, epub, kindle and other format this book has been release on 1992 with Business & Economics categories.

The so-called classical system of current U.S. tax law treats corporations and their investors as separate entities and levies tax at both the corporate and shareholder levels on earnings from investments in corporate equity. Corporate earnings distributed to lenders as interest are generally deductible by the corporation and taxed, if at all, to the lender. Investors who conduct business activity in noncorporate form, such as a sole proprietorship or partnership, are taxed once on their earnings at the owners' tax rate. As a result, despite the critical role played by corporations as a vehicle for economic growth, the United States tax law often perversely penalizes the corporate form of organization. The current system of taxation also distorts corporate financial decisions in particular by encouraging debt and discouraging new equity financing of corporate investments. The tax system also prejudices corporate decisions about whether to retain earnings or pay dividends and encourages corporations to distribute earnings in a manner to avoid the double-level tax. Integration of the individual and corporate tax system would tax corporate income once and reduce or eliminate these economic distortions. Most trading partners of the United States have integrated their corporate tax systems. The potential economic gains from integration are substantial. This Report examines in detail several different integration prototypes, although it does not attempt an exhaustive discussion of all possible integration systems or of all the technical issues raised by the alternative prototypes. This Report does not contain legislative recommendations. Rather, it is intended to stimulate discussion of the various prototypes and issues they raise. By advancing the opportunity for such debate, this Report should encourage serious consideration of proposals for integrating the individual and corporate tax systems in the United States.

Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law

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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2012

Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law written by Guglielmo Maisto and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012 with Corporations categories.

This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.

Tax Policy And Capital Formation

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Author : United States. Congress. Joint Committee on Taxation
language : en
Publisher:
Release Date : 1977

Tax Policy And Capital Formation written by United States. Congress. Joint Committee on Taxation and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1977 with Capital investments categories.

Comparison Of Us Uk And German Corporate Income Tax Systems With Respect To Dividend Relief

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Author : Benjamin Mahr
language : en
Publisher: GRIN Verlag
Release Date : 2007

Comparison Of Us Uk And German Corporate Income Tax Systems With Respect To Dividend Relief written by Benjamin Mahr and has been published by GRIN Verlag this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with categories.

Essay from the year 2004 in the subject Business economics - Accounting and Taxes, grade: Distinction (83%), The University of Sydney (Faculty of Law), course: Comparative Corporate Taxation, language: English, abstract: This essay briefly describes the main different theoretical approaches (tax systems) designed to alleviate the double burden of corporation tax and shareholder income tax under Part 2. Parts 3- 5 explain how the problem of dividend double taxation was tried to be solved in the heterogeneous tax systems of the Germany, the UK and the US. However, the essay will not cover the different double tax avoiding treaties in force in those countries.