Download or read book Controlled Foreign Company Legislation written by Organisation for Economic Co-operation and Development and published by OECD. This book was released on 1996 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt: A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.
Download or read book Controlled Foreign Companies written by Lee Burns and published by . This book was released on 1992 with total page 304 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is an explanation of Australia's CFC rules. It places the legislation in context, provides a framework for analysing problems and describes the new regime in detail.
Download or read book The Taxation of Controlled Foreign Corporations written by John Prebble and published by . This book was released on 1987 with total page 86 pages. Available in PDF, EPUB and Kindle. Book excerpt: Study on the taxation of controlled foreign corporation in New Zealand with reference to other country's approach.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules Action 3 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 75 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 3.
Download or read book Proposal Relating to Current U S Taxation of Certain Operations of Controlled Foreign Corporations H R 2889 American Jobs and Manufacturing Preservation Act of 1991 and Related Issues written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1991 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book CFCs general Overview written by Lowell D. Yoder and published by . This book was released on 2010-01 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "Describes the general rules for U.S. income taxation of United States shareholders of controlled foreign corporations (CFCs) under Subpart F. It begins with a discussion of the background and legislative history of Subpart F. A detailed analysis is provided of the ownership tests that must be satisfied for Subpart F to apply, including such key terms as "controlled foreign corporation," "United States person," and "United States shareholder." This portfolio also describes the categories of items included in U.S. shareholders' income under Subpart F, and the rules for determining the amounts includible in income and the U.S. tax treatment. It further provides an overview of the tax results to U.S. shareholders of various transactions involving CFCs, including the organization and reorganization of a CFC, CFC distributions, and liquidations and dispositions of CFCs. Finally, it describes the rules coordinating Subpart F with other special rules that apply to foreign entities and summarizes the return and compliance rules that apply to CFCs."
Download or read book Controlled Foreign Corporations 1980 written by United States. Internal Revenue Service and published by . This book was released on 1984 with total page 120 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Controlled Foreign Corporations as Fiscally Transparent Entities written by Daniele Canè and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Controlled foreign corporation rules are a fundamental piece of the international tax regime. They preserve national tax bases from erosion and profit shifting, counteract tax deferral and implement capital export neutrality policies. However, the application of these rules should be coordinated at treaty level, which would also serve to avoid undesirable policy effects. The legal framework of tax treaties, as integrated by the Multilateral Convention (MLI), is now ready to support such a coordinated application of CFC rules. The new set of provisions for transparent entities can be used to this end, on the assumption that certain CFCs should also be treated as transparent entities. Indeed, CFC rules patterned after the transparency approach produce effects and involve problems comparable to transparent partnerships. This article elaborates on some of these problems and illustrates how the new provisions dedicated to transparent entities interact with each other and allow a balanced application of treaties to CFCs as well.Full-text Paper.
Download or read book Supplemental Statistics of Income written by United States. Internal Revenue Service and published by . This book was released on 1979 with total page 248 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Controlled Foreign Corporations as Fiscally Transparent Entities the Application of CFC Rules in Tax Treaties written by D. Canè and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Controlled foreign corporation rules are a fundamental piece of the international tax regime. They preserve national tax bases from erosion and profit shifting, counteract tax deferral and implement capital export neutrality policies. However, the application of these rules should be coordinated at treaty level, which would also serve to avoid undesirable policy effects. The legal framework of tax treaties, as integrated by the Multilateral Convention (MLI), is now ready to support such a coordinated application of CFC rules. The new set of provisions for transparent entities can be used to this end, on the assumption that certain CFCs should also be treated as transparent entities. Indeed, CFC rules patterned after the transparency approach produce effects and involve problems comparable to transparent partnerships. This article elaborates on some of these problems and illustrates how the new provisions dedicated to transparent entities interact with each other and allow a balanced application of treaties to CFCs as well.
Download or read book The Taxation of Controlled Foreign Corporations written by John Prebble QC and published by . This book was released on 2015 with total page 41 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 1987, New Zealand taxpayers could avoid tax by establishing foreign corporations in which they held a controlling shareholding in low tax jurisdictions. This avoidance could occur in two ways. First, through using the foreign corporation to intercept passive income, such as interest or royalties, that would otherwise be taxed to the shareholders. Secondly, by using a foreign corporation as an investment vehicle for accumulated profits, thus sheltering investment income that would otherwise accrue to the shareholders. Six countries, the United States of America, Canada, France, the Federal Republic of Germany, and Japan, were sufficiently concerned about these problems to enact controlled foreign corporation legislation. Broadly, these countries adopt two methods to determine which income will be subject to taxation: the transactional approach and the jurisdictional approach. The jurisdictional approach is simple, relative to the transactional approach, but for all countries, the legislation is complicated. The author compares the relative merits of each country's legislation, concluding that the United Kingdom offers the most satisfactory model with the lowest compliance and administrative costs. In 1993, New Zealand adopted controlled foreign company legislation modelled on the United Kingdom's approach.
Download or read book Tax Treaties and Controlled Foreign Company Legislation Pushing the Boundaries written by Daniel Sandler and published by Kluwer Law International B.V.. This book was released on 1998-07-29 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.
Download or read book Concept and Implementation of CFC Legislation written by Nathalie Bravo and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 423 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.
Download or read book Disregarded Entities written by Howard E. Abrams and published by . This book was released on 2006 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ... discusses entities that are recognized as having a legal status separate from their owners for certain purposes but are totally ignored for federal income tax purposes. The three types of disregarded entities are entities disregarded under the elective classification regime, qualified S corporation subsidiaries, and qualified real estate investment trust subsidiaries. For each type of entity, qualification, formation, conversion, operation, and termination issues are addressed along with use of the entity in specific contexts including corporate reorganizations, partnership transactions, and like-kind exchanges. Application of specific provisions such as the at-risk rules and the cancellation of indebtedness provisions are discussed. Use of disregarded entities in cross-border transactions and their impact on the direct and indirect foreign tax credit also are described.
Download or read book CFCs investment of Earnings in United States Property written by Philip Fried (Lawyer) and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "...analyzes the U.S. income tax consequences under §956 of the Internal Revenue Code of investments of earnings and profits by controlled foreign corporations in United States property. This Portfolio discusses the circumstances under which such investments may result in the taxation to the company's U.S. shareholders of a portion of the company's earnings and profits, and it explains the rules governing the computation of such income inclusion. It describes the possibility of unexpected results from the operation of the §956 rules, and it suggests planning possibilities to avoid pitfalls. Among the matters discussed are the definition of the term "United States property" and the exceptions thereto; calculations of the amount of a controlled foreign corporation's earnings and profits invested in United States property and the effect of distributions on such calculations; special rules regarding the taxation of U.S. shareholders, including the applicable foreign tax credit rules; and tax planning opportunities."
Download or read book Controlled Foreign Corporations written by Frank Stockmann and published by . This book was released on 2001 with total page 318 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book CFC Legislation Tax Treaties and EC Law written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2004-01-01 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of 23 national reports dealing with domestic CFC provisions and the influence of tax treaties and EC law on CFC legislation and a summarising general report, originating from a joint conference on CFC legislation in Rust (Austria) from 3-6 July 2003.
