Download or read book Corporate Income Taxes under Pressure written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2021-02-26 with total page 388 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.

Download or read book Statistics of Income written by and published by . This book was released on 1980 with total page 174 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle written by Eva Escribano and published by Kluwer Law International B.V.. This book was released on 2019-05-10 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt: Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.

Download or read book Federal Income Taxation of Corporations and Partnerships written by Richard L. Doernberg and published by Aspen Publishers. This book was released on 2000 with total page 992 pages. Available in PDF, EPUB and Kindle. Book excerpt: A return to coverage of partnerships and limited liability companies highlights the Third Edition of Federal Income Taxation of Corporations and Partnerships. with more of the extremely effective problems that gained it such widespread praise, this flexible casebook is now completely updated for use in a wide variety of course offerings. To simplify the intricacies of the taxation of business enterprises, the authors: use problems and examples in almost every chapter - in addition to cases and notes illustrate typical commercial transactions emphasize major themes of policy and practice keep the book flexible enough to be used in two-, three-, or four-credit courses Federal Income Taxation of Corporations and Partnerships, Third Edition, is logically organized into three main parts: Corporations S Corporations Partnerships The Third Edition reflects recent developments in corporate and partnership taxation: 10 full chapters on partnership taxation including new materials that address the explosive growth of limited liability companies and hybrid entities new debt/equity limitations in corporate formations and reorganizations anti-abuse redemption provisions covering stock options and sales between related corporations the Anti-Morris Trust changes to tax-free spin-offs new elective classification regulations liberalization of Subchapter S shareholder restrictions and changes to timing of Subchapter S distributions, and Qualified Subchapter S Subsidiaries

Download or read book Fundamentals of Corporate Taxation written by Stephen A. Lind and published by West Publishing Company. This book was released on 1997 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book A Complete Introduction to Corporate Taxation written by Reginald Mombrun and published by . This book was released on 2006 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: Most books on the taxation of C corporations ignore important parts of this area, such as affiliated corporations and the filing of consolidated returns. This book, in addition to discussing the rules of Subchapter C, also introduces the concepts of affiliated corporations and the important area of consolidated returns. Hence, the reader receives a complete view of corporate taxation. Part I of the book introduces the tools and terms used by corporate tax lawyers. Part II discusses the taxation of C corporations in general. Part III discusses corporate distributions. Part IV, which covers the major areas of practice, contains an extensive discussion of corporate liquidations, distributions and reorganizations. Part V discusses controlled corporations, affiliated corporations and consolidated returns. "The book is very thorough and detailed . . . While the book can certainly be used as a text, it could also serve as a valuable library resource to anyone seeking a general understanding of the structure of the corporate tax system . . . Highly recommended." -- CHOICE Magazine

Download or read book Source Book of Statistics of Income written by and published by . This book was released on 2007 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Federal Income Taxation of S Corporations written by KAREN C.. MCNULTY BURKE (JOHN K.) and published by Foundation Press. This book was released on 2022-10-20 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This text provides a concise introduction to the taxation of S corporations and their shareholders. It explains the basic law and offers examples to focus the scope and application of the general principles. Topics include: electing and maintaining S status; shareholder-level taxation of income, loss, and distributions; use of shareholder debt; qualified subchapter S subsidiaries; and special taxes imposed on S corporations. More advanced topics are also addressed, including redemptions, acquisitions and dispositions, as well as the advantages and disadvantages of S corporations compared to partnerships. This third edition has been fully updated to reflect developments through June 2022.

Download or read book Illinois State Budget written by Illinois. Governor and published by . This book was released on 2007 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Federal Corporate Taxation written by Howard E. Abrams and published by . This book was released on 1990 with total page 312 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Fourth Edition of Abrams & Doernberg's Federal Corporate Taxation includes: * New debt/equity limitations ("non-qualified preferred stock") in corporate formations & reorganizations * Anti-abuse redemption provisions covering stock options & sales between related corporations * The anti-Morris Trust changes to tax-free spin-offs * Liberalization of Subchapter S shareholder restrictions & changes to timing of Subchapter S distributions ###1-56662-799-0

Download or read book Practical Guide to Corporate Taxation written by Dominic Daher and published by Cch Incorporated. This book was released on 2012-02-14 with total page 357 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to C Corporations offer practitioners current and practical explanation and analysis on corporations, giving them the guidance needed to manage the C Corporation election, compliance, tax planning, and life cycle needs. In addition to thorough coverage of how the tax laws impact C corporations, the Practical Guide details corporate formation, distributions, redemptions, liquidations, reorganizaitons and issues related to corporate tax practice and procedure. Practical Guide to C Corporations provides business entity practitioners with complete coverage of C corporation taxation issues.

Download or read book Taxation of Regulated Investment Companies and Their Shareholders written by Susan A. Johnston and published by Warren Gorham & Lamont. This book was released on 1999-01-01 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book State Taxation written by Jerome R. Hellerstein and published by . This book was released on 1998 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International Company Taxation and Tax Planning written by Dieter Endres and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.

Download or read book Corporate Taxation Group Debt Funding and Base Erosion written by Gianluigi Bizioli and published by Kluwer Law International. This book was released on 2020-02-07 with total page 280 pages. Available in PDF, EPUB and Kindle. Book excerpt: The EU's Anti-Tax Avoidance Directive (ATAD), implemented in January 2019, confronts Member States with complex challenges, particularly via the introduction of an interest limitation rule. This timely book, the first in-depth analysis of the features and implications of the directive, provides insightful and practical discussions by experts from around Europe on the crucial interactions of the ATAD with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms. Specific issues and topics covered include the following: relation with the OECD's Base Erosion and Profit Sharing project (BEPS) and the EU's Common Corporate Tax Base initiative; technical subjects relating to corporate taxation and debt funding; problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies; exclusion clauses for interest expenses; and interplay between interest limitation rules and anti-hybrid rules. A comparative analysis of implementation issues in four leading Member States--Germany, Italy, Spain and The Netherlands--as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated to the implementation of the ATAD. This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States.

Download or read book Subchapter S Taxation written by Irving M. Grant and published by Shepard's/McGraw-Hill. This book was released on 1980-01-01 with total page 700 pages. Available in PDF, EPUB and Kindle. Book excerpt: This looseleaf work is a comprehensive analysis of the provisions of Subchapter S of the IRC. Comparisons of Subchapter S corporations with partnerships & discussions of how Subchapter S elections may be used to reduce taxes are included in the volume. Forms for Subchapter S election & revocation are provided.

Download or read book Taxation of S Corporations in a Nutshell written by Douglas A. Kahn and published by West Academic Publishing. This book was released on 2020-10-07 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Subchapter S rules are complex. This book describes the basic rules that apply to S corporations and their shareholders with sufficient detail to alert the reader to potential pitfalls. The topics covered include: (1) the qualification requirements for a Subchapter S election, (2) the allocation of tax items among the shareholders, (3) the effect of those allocations on a shareholder's basis in stock and debt, (4) the limitations on the deduction of pass through items, (5) the treatment of corporate distributions, (6) the voluntary and involuntary termination of Subchapter S status, (7) the treatment of the year in which a Subchapter S election is terminated, (8) the limited availability of certain Subchapter S provisions after a Subchapter S election is terminated, (9) the taxation of an S corporation's passive investment income and built-in gains, and (10) the business income deduction. The discussion of these issues is supplemented by numerous examples.