Download or read book Comparison of US UK and German corporate income tax systems with respect to dividend relief written by Benjamin Mahr and published by GRIN Verlag. This book was released on 2004-08-12 with total page 29 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Anglo American Corporate Taxation written by Steven A. Bank and published by Cambridge University Press. This book was released on 2011-09-22 with total page 265 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
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Book Details:
- Author : Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs
- Publisher : Paris, France : Organisation for Economic Co-operation and Development ; [Washington, D.C. : Sales agents, OECD Publications and Information Center]
- Release : 1983
- ISBN :
- Pages : 212 pages
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Download or read book Corporate shareholder Income Taxation and Allocating Taxing Rights Between Countries written by Peter Andrew Harris and published by . This book was released on 1996 with total page 948 pages. Available in PDF, EPUB and Kindle. Book excerpt: This ground-breaking book from the IBFD proposes a fundamental change to the norms for the allocation of taxing rights among countries. The author uses an in-depth study of imputation systems to expose the flaws in the current international order, arguing that it is theoretically unsound. He then develops an alternative that would resolve many of the problems presented by international tax law today. Imputation systems are founded on a philosophy that corporations are not appropriate subjects of income taxation, other than as vehicles for the collection of tax, & they accordingly seek to alleviate economic double taxation. In practice they do not achieve this aim. In a domestic context, considered in the first four chapters, their inconsistencies & inaccuracies obscure the more fundamental flaws of the income taxation systems of which they form a part. In an international context, considered in the second four chapters, the difficulties associated with imputation systems highlight the deficiencies in current norms for the allocation of taxing rights among countries. The author examines those norms & finds them an inadequate basis for the international order. The alternatives he proposes would place the international taxing order on a firm theoretical footing & could be applied to any type of corporate tax system. If adopted, his proposals would obviate the need for much current international tax law. Treaties, measures for the avoidance of double taxation & many anti-avoidance measures would become superfluous. This extremely important book, based on prize-winning doctoral research, is destined to become a classic in the field. The acute perception & explication of theories underpinning international taxation make it essential reading.