Author: Samuel D. Brunson
Publisher:
ISBN:
Category :
Languages : en
Pages : 58
Book Description
Mutual funds and other regulated investment companies currently occupy a central space in American households' financial lives. Is spite of their near-ubiquity, though, regulated investment companies occupy a strange tax limbo as quasi-pass-through entities, neither fully taxable nor fully tax-transparent. To qualify for this quasi-pass-through status, regulated investment companies must, among other things, distribute the bulk of their income to shareholders annually. The distribution requirement imposes costs on both regulated investment companies and on their shareholders. It is commonly framed as an attempt to make the economics of investing in regulated investment companies similar to the economics of making direct portfolio investments. History shows, though, that the distribution requirement finds its basis in marketing, and not in any tax policy consideration. If the distribution requirement benefited the shareholders or the government, it would be worth the costs it imposes. But this article concludes that the complexity and expense are not. When tax policymakers discard their flawed premise of attempting to replicate the tax treatment of direct portfolio investment, they can stop clumsily and partially attempting to recreate true pass-through taxation for regulated investment companies. Instead, they can reframe regulated investment company taxation in a way that imposes a single level of taxation while, at the same time, protects regulated investment companies from being transformed into vehicles for tax deferral.In this Article, I evaluate several ways the tax law could tax regulated investment companies and their shareholders while imposing only a single level of taxation and ensuring that shareholders have the liquidity with which to pay taxes. Ultimately, I find that the best model would exempt regulated investment companies from taxation. At the same time, it would defer taxing shareholders until they realized income or gain. It would make up for that deferral by imposing an interest charge on the gain. For shareholders who wanted to avoid this interest regime, it would also allow for a mark-to-market election.
The Taxation of RICs
Author: Samuel D. Brunson
Publisher:
ISBN:
Category :
Languages : en
Pages : 58
Book Description
Mutual funds and other regulated investment companies currently occupy a central space in American households' financial lives. Is spite of their near-ubiquity, though, regulated investment companies occupy a strange tax limbo as quasi-pass-through entities, neither fully taxable nor fully tax-transparent. To qualify for this quasi-pass-through status, regulated investment companies must, among other things, distribute the bulk of their income to shareholders annually. The distribution requirement imposes costs on both regulated investment companies and on their shareholders. It is commonly framed as an attempt to make the economics of investing in regulated investment companies similar to the economics of making direct portfolio investments. History shows, though, that the distribution requirement finds its basis in marketing, and not in any tax policy consideration. If the distribution requirement benefited the shareholders or the government, it would be worth the costs it imposes. But this article concludes that the complexity and expense are not. When tax policymakers discard their flawed premise of attempting to replicate the tax treatment of direct portfolio investment, they can stop clumsily and partially attempting to recreate true pass-through taxation for regulated investment companies. Instead, they can reframe regulated investment company taxation in a way that imposes a single level of taxation while, at the same time, protects regulated investment companies from being transformed into vehicles for tax deferral.In this Article, I evaluate several ways the tax law could tax regulated investment companies and their shareholders while imposing only a single level of taxation and ensuring that shareholders have the liquidity with which to pay taxes. Ultimately, I find that the best model would exempt regulated investment companies from taxation. At the same time, it would defer taxing shareholders until they realized income or gain. It would make up for that deferral by imposing an interest charge on the gain. For shareholders who wanted to avoid this interest regime, it would also allow for a mark-to-market election.
Publisher:
ISBN:
Category :
Languages : en
Pages : 58
Book Description
Mutual funds and other regulated investment companies currently occupy a central space in American households' financial lives. Is spite of their near-ubiquity, though, regulated investment companies occupy a strange tax limbo as quasi-pass-through entities, neither fully taxable nor fully tax-transparent. To qualify for this quasi-pass-through status, regulated investment companies must, among other things, distribute the bulk of their income to shareholders annually. The distribution requirement imposes costs on both regulated investment companies and on their shareholders. It is commonly framed as an attempt to make the economics of investing in regulated investment companies similar to the economics of making direct portfolio investments. History shows, though, that the distribution requirement finds its basis in marketing, and not in any tax policy consideration. If the distribution requirement benefited the shareholders or the government, it would be worth the costs it imposes. But this article concludes that the complexity and expense are not. When tax policymakers discard their flawed premise of attempting to replicate the tax treatment of direct portfolio investment, they can stop clumsily and partially attempting to recreate true pass-through taxation for regulated investment companies. Instead, they can reframe regulated investment company taxation in a way that imposes a single level of taxation while, at the same time, protects regulated investment companies from being transformed into vehicles for tax deferral.In this Article, I evaluate several ways the tax law could tax regulated investment companies and their shareholders while imposing only a single level of taxation and ensuring that shareholders have the liquidity with which to pay taxes. Ultimately, I find that the best model would exempt regulated investment companies from taxation. At the same time, it would defer taxing shareholders until they realized income or gain. It would make up for that deferral by imposing an interest charge on the gain. For shareholders who wanted to avoid this interest regime, it would also allow for a mark-to-market election.
Taxation of Regulated Investment Companies and Their Shareholders
Author: Richard M. Hervey
Publisher:
ISBN: 9781633590809
Category : Mutual funds
Languages : en
Pages :
Book Description
"... discusses in detail the provisions of [sections] 851 through 855, 860 and 4982 of the Internal Revenue Code, which govern the taxation of regulated investment companies (RICs). The portfolio also discusses the applicability of other Code provisions to RICs"--Page iii.
Publisher:
ISBN: 9781633590809
Category : Mutual funds
Languages : en
Pages :
Book Description
"... discusses in detail the provisions of [sections] 851 through 855, 860 and 4982 of the Internal Revenue Code, which govern the taxation of regulated investment companies (RICs). The portfolio also discusses the applicability of other Code provisions to RICs"--Page iii.
Taxation of Regulated Investment Companies and Their Shareholders
Author: Susan A. Johnston
Publisher: Warren Gorham & Lamont
ISBN: 9780791337639
Category : Mutual funds
Languages : en
Pages :
Book Description
Publisher: Warren Gorham & Lamont
ISBN: 9780791337639
Category : Mutual funds
Languages : en
Pages :
Book Description
Taxation of Regulated Investment Companies
Author: Richard M. Hervey
Publisher:
ISBN: 9781558716223
Category : Mutual funds
Languages : en
Pages :
Book Description
... discusses in detail the provisions of [sections] 851 through 855, 860 and 4982 of the Internal Revenue Code, which govern the taxation of regulated investment companies (RICs). The portfolio also discusses the applicability of other Code provisions to RICs.
Publisher:
ISBN: 9781558716223
Category : Mutual funds
Languages : en
Pages :
Book Description
... discusses in detail the provisions of [sections] 851 through 855, 860 and 4982 of the Internal Revenue Code, which govern the taxation of regulated investment companies (RICs). The portfolio also discusses the applicability of other Code provisions to RICs.
Value Added Tax and Its Impact on Property Management
Author: Royal Institution of Chartered Surveyors
Publisher:
ISBN: 9780854066971
Category : Finance
Languages : en
Pages : 11
Book Description
Publisher:
ISBN: 9780854066971
Category : Finance
Languages : en
Pages : 11
Book Description
National Taxation for Property Management and Valuation
Author: A Macleary
Publisher: Taylor & Francis
ISBN: 1135833230
Category : Architecture
Languages : en
Pages : 189
Book Description
A clear and up-to-date guide to the UK tax system for surveyors and valuers which demonstrates land valuation for taxation purposes.
Publisher: Taylor & Francis
ISBN: 1135833230
Category : Architecture
Languages : en
Pages : 189
Book Description
A clear and up-to-date guide to the UK tax system for surveyors and valuers which demonstrates land valuation for taxation purposes.
The R.I.C.S. handbook of community land and development taxation
Author: Robert G. Edwards
Publisher:
ISBN: 9780903393263
Category :
Languages : en
Pages :
Book Description
Publisher:
ISBN: 9780903393263
Category :
Languages : en
Pages :
Book Description
Taxation of Foreign Investment in U.S. Real Estate
Author: United States. Department of the Treasury
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 84
Book Description
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 84
Book Description
The R. I. C. S. Handbook of Community Land and Development Taxation: Development taxation
Briefings for Surveyors
Author:
Publisher:
ISBN: 9780946700325
Category : Capital gains tax
Languages : en
Pages : 0
Book Description
Publisher:
ISBN: 9780946700325
Category : Capital gains tax
Languages : en
Pages : 0
Book Description