Download or read book Tax Loss Utilization and Corporate Groups written by Stephen R. Richardson and published by . This book was released on 2013 with total page 25 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax loss utilization and corporate groups written by and published by . This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The less restriction there is in the tax system on the effective transfer of losses, the higher the price that will be paid to the seller, which will tend toward the limit of its full tax value. [...] In such cases, the deferral of deductions for a loss-carrying corporation tends to increase the marginal tax rate on investment above what it would be in a system of 25 For example, the general relationship requirement in the U. S. for tax consolidation is 80 per cent ownership, and the requirement in the U. K. for tax loss transfer is 75 per cent ownership. [...] The Extent of the Issue The current non-refundable loss system is costly to the taxpayer to the extent that tax loss transfer involves uncertainty and expense, and because of foregone interest on the deferral of the tax refund. [...] According to summary data presented in the Department of Finance's "The Taxation of Corporate Groups,"30 the stock of unused losses in 2008 was $206 billion, or nearly 100 per cent of corporate taxable income for the same year.31 Assuming a 25 per cent effective tax rate and a five per cent nominal rate of interest, the cost of carrying this stock for a single year is on the order of "only" $5 bil [...] The foregoing discussion of the treatment of corporate tax losses in the Canadian corporate tax system suggests that the current system raises issues of horizontal equity and economic efficiency, including the issue of loss utilization within corporate groups.
Download or read book Corporate Loss Utilisation through Aggressive Tax Planning written by OECD and published by OECD Publishing. This book was released on 2011-08-03 with total page 92 pages. Available in PDF, EPUB and Kindle. Book excerpt: After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.
Download or read book Taxation of Corporate Groups written by Miguel Correia and published by . This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book proposes an interdisciplinary and comparative approach to the taxation of corporate groups. Chapter 1 analyses the core mechanical pillars of corporate income tax (CIT) systems and their impact on corporate behaviour. Chapter 2 first analyses the economic, legal and functional nature of corporate groups. Then, it examines the fundamental mechanical operation of CIT systems assuming that no tax integration solution, such as group taxation or flow-through taxation, is applicable, and assesses the merits and shortfalls of taxing corporate groups in this manner. Conversely, in chapter 3 the book analyses how corporate groups may be taxed under tax integration solutions and investigates the consequences of adopting such a stance. The study concludes, in chapter 4, by proposing a set of policy guidelines that should be considered when approaching the taxation of corporate groups.
Download or read book Income Tax Treatment of Cooperatives Handling of losses written by Donald A. Frederick and published by . This book was released on 1993 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Shipowners Limitation of Liability written by Miguel Correia and published by Kluwer Law International B.V.. This book was released on 2013-01-06 with total page 405 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book refines the features of a variety of different common law and civil law systems down to a recognizable standard CIT system, identifying in the process the system’s core strengths and problems, as well as the factors that determine its impact on corporate behavior. The author offers insightful perspectives on such crucial issues as the following: corporate group members versus corporate groups as taxable entities; anti-abuse rules and developments in judicial anti-abuse doctrines; costs associated with, e.g., valuation of assets, compliance, and administration; how certain core CIT concepts are independent of tax law; efficiency, equity, and the protection of existing property rights; the firm’s reaction to behavioral control instruments; limitations on the use of losses; depreciation and amortization rules; manipulation of legal characterization; and transfer of assets and income. The work has an interdisciplinary approach drawing on the literatures of tax law, economics, corporate law, accounting, and business management. It concludes with a set of policy guidelines that should be considered when approaching the traditionally cumbersome interaction between tax systems and corporate groups. Especially valuable to the practitioner are the book’s extensive graphic design solutions illustrating the subtleties of the operation of corporate tax laws. Analyzing the taxation of corporate groups in a user-friendly form not available in any other source, this book greatly enhances the development of advanced tax planning methods that do not disrupt the economic operation of businesses. Its comprehensive conceptual framework will greatly facilitate the work of those, from practitioners to researchers, interested in developing a practical approach to corporate income taxation applicable at a global level.
Download or read book Tax on Unrelated Business Income of Exempt Organizations written by United States. Internal Revenue Service and published by . This book was released on 1979 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Taxation of Corporate Groups Under Consolidation written by Antony Ting and published by . This book was released on 2013 with total page 321 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The rise of corporate groups in the last century dictates a shift in the income tax law: instead of treating each company as a separate taxpayer, the tax consolidation regime is increasingly common. Antony Ting presents the first comprehensive comparative study of eight consolidation regimes in Australia, France, Italy, Japan, the Netherlands, New Zealand, Spain and the USA. In the study, he critically analyses and compares alternative policy options with respect to ten key structural elements. The study improves understanding of the design and implementation of consolidation regimes and sets the stage for the search for a model. It provides valuable information with respect to the best practices, as well as the pitfalls, in the design of a consolidation regime. The book is essential to countries contemplating the introduction of a new consolidation regime and offers important insights into the management of such a complex structure through careful policy-orientated choices"--
Download or read book United States Code written by United States and published by . This book was released on 2013 with total page 1506 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.
Download or read book The Taxation of Corporate Groups Under Consolidation written by Antony Ting and published by Cambridge University Press. This book was released on 2013 with total page 339 pages. Available in PDF, EPUB and Kindle. Book excerpt: Antony Ting presents the first comprehensive comparative study of the tax consolidation regimes adopted in eight countries.
Download or read book Circular A Agricultural Employer s Tax Guide written by and published by . This book was released on 1992 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Self employment Tax written by and published by . This book was released on 1988 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Instructions for Schedule D Form 1120S Capital Gains and Losses and Built in Gains written by United States. Internal Revenue Service and published by . This book was released on 1995 with total page 8 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Law Design and Drafting Volume 1 written by Mr.Victor Thuronyi and published by International Monetary Fund. This book was released on 1996-08-23 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.
Download or read book Introduction to Business written by Lawrence J. Gitman and published by . This book was released on 2024-09-16 with total page 1455 pages. Available in PDF, EPUB and Kindle. Book excerpt: Introduction to Business covers the scope and sequence of most introductory business courses. The book provides detailed explanations in the context of core themes such as customer satisfaction, ethics, entrepreneurship, global business, and managing change. Introduction to Business includes hundreds of current business examples from a range of industries and geographic locations, which feature a variety of individuals. The outcome is a balanced approach to the theory and application of business concepts, with attention to the knowledge and skills necessary for student success in this course and beyond. This is an adaptation of Introduction to Business by OpenStax. You can access the textbook as pdf for free at openstax.org. Minor editorial changes were made to ensure a better ebook reading experience. Textbook content produced by OpenStax is licensed under a Creative Commons Attribution 4.0 International License.
Download or read book Medical and Dental Expenses written by and published by . This book was released on 1990 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Farmer s Tax Guide written by and published by . This book was released on 1998 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt:
