Integration Of The Corporate And Shareholder Tax Systems
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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 Capital gains tax 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.
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.
Exposure Draft
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Author : American Institute of Certified Public Accountants. Tax Division
language : en
Publisher:
Release Date : 1992
Exposure Draft 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 1992 with Corporations categories.
Report Of The Department Of The Treasury On Integration Of The Individual And Corporate Tax Systems
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Author : United States Dept Of The Treasury
language : en
Publisher: Forgotten Books
Release Date : 2017-10-31
Report Of The Department Of The Treasury On Integration Of The Individual And Corporate Tax Systems written by United States Dept Of The Treasury and has been published by Forgotten Books this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-10-31 with Business & Economics categories.
Excerpt from Report of the Department of the Treasury on Integration of the Individual and Corporate Tax Systems: Taxing Business Income Once 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. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.
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.
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 Business & Economics 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.
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.
Anglo American Corporate Taxation
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Author : Steven A. Bank
language : en
Publisher: Cambridge University Press
Release Date : 2011-09-22
Anglo American Corporate Taxation written by Steven A. Bank and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011-09-22 with Law categories.
The UK and the USA have historically represented opposite ends of the spectrum in their approaches to taxing corporate income. Under the British approach, corporate and shareholder income taxes have been integrated under an imputation system, with tax paid at the corporate level imputed to shareholders through a full or partial credit against dividends received. Under the American approach, by contrast, corporate and shareholder income taxes have remained separate under what is called a 'classical' system in which shareholders receive little or no relief from a second layer of taxes on dividends. Steven A. Bank explores the evolution of the corporate income tax systems in each country during the nineteenth and twentieth centuries to understand the common legal, economic, political and cultural forces that produced such divergent approaches and explains why convergence may be likely in the future as each country grapples with corporate taxation in an era of globalization.
The Taxation Of Corporations And Shareholders In Israel
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Author : David Gliksberg
language : en
Publisher:
Release Date : 2015
The Taxation Of Corporations And Shareholders In Israel written by David Gliksberg and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015 with categories.
The Israeli model of taxation of corporations and shareholders is based on a partial integration model. This regime has two components which create the partial integration: First, the reduced corporate income tax rate at the corporate level on distributed and retained earnings. Second, the reduced income tax rate at the shareholders (individuals) level on dividends. The regime had been developed gradually during the years and it was considered a reasonable system, on comparative level, from theoretical and practical perspectives. Following the developments of attractive income and corporate tax regimes worldwide, the Israeli system might be considered as an old approach that required several fundamental adjustments. After the drastic reduction of the inflation rate in Israel and the successful operation of the comprehensive adjustment of the income tax to inflation, the issue of the desirable tax regime on corporate and shareholder income has been placed at the top of the fiscal agenda. The article suggests that the regime of partial integration should be replaced, by a new regime that will maximize equity and efficiency, based, inert alia, on the international experience of foreign tax regime.