Author: Leandra Lederman Publisher: LexisNexis ISBN: 9781422474433 Category : Corporations Languages : en Pages : 0
Book Description
This clearly written Understanding treatise is designed to supplement any corporate tax casebook, providing a step-by-step explanation of the fundamentals of corporate tax law. After an initial introductory chapter, six chapters cover events in the life cycle of a corporation, including capitalization of a corporation with debt or equity. The next seven chapters cover S corporations; corporate reorganizations (in four chapters); carryover of tax attributes; and anti-abuse and special provisions, such as the corporate AMT. The final two chapters discuss the important policy issues of corporate integration and corporate tax shelters. The chapter on corporate tax shelters is new to this edition of the book. Understanding Corporate Taxation includes discussion of relevant cases, checklists, diagrams of transactions, and numerous examples.
Author: Ruud A. de Mooij Publisher: International Monetary Fund ISBN: 1513511777 Category : Business & Economics Languages : en Pages : 388
Book Description
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.
Author: Howard E. Abrams Publisher: ISBN: Category : Corporations Languages : en Pages : 312
Book Description
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
Author: Eva Escribano Publisher: Kluwer Law International B.V. ISBN: 940350644X Category : Law Languages : en Pages : 249
Book Description
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.
Author: Reginald Mombrun Publisher: ISBN: Category : Business & Economics Languages : en Pages : 360
Book Description
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
Author: Stephen Schwarz Publisher: West Academic Publishing ISBN: 9781642428933 Category : Languages : en Pages : 402
Book Description
This comprehensive and clearly written text is designed to help students recognize and understand the basic principles and issues covered in law school courses in corporate taxation at both the J.D. and LL.M. levels. It explains all the fundamental concepts and transactions affecting C and S corporations and their shareholders, and includes numerous illustrative examples, self-test questions with answers, and sample exam questions. The Ninth Edition incorporates all relevant provisions of the 2017 legislation known as the Tax Cuts and Jobs Act.
Author: Alan J. Auerbach Publisher: Cambridge University Press ISBN: 1139464515 Category : Business & Economics Languages : en Pages : 401
Book Description
This book was first published in 2007. Most countries levy taxes on corporations, but the impact - and therefore the wisdom - of such taxes is highly controversial among economists. Does the burden of these taxes fall on wealthy shareowners, or is it passed along to those who work for, or buy the products of, corporations? Can a country with high corporate taxes remain competitive in the global economy? This book features research by leading economists and accountants that sheds light on these and related questions, including how taxes affect corporate dividend policy, stock market value, avoidance, and evasion. The studies promise to inform both future tax policy and regulatory policy, especially in light of the Sarbanes-Oxley Act and other actions by the Securities and Exchange Commission that are having profound effects on the market for tax planning and auditing in the wake of the well-publicized accounting scandals in Enron and WorldCom.
Author: Peter Harris Publisher: Cambridge University Press ISBN: 1107033535 Category : Business & Economics Languages : en Pages : 651
Book Description
A comprehensive and comparative analysis of corporate tax systems, focusing on structural defects and how they are addressed in practice.
Author: Gianluigi Bizioli Publisher: Kluwer Law International ISBN: 9789403511702 Category : Languages : en Pages : 280
Book Description
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.
Author: Leandra Lederman
Author: Ruud A. de Mooij
Author: Howard E. Abrams
Author: Eva Escribano
Author: Reginald Mombrun
Author: Stephen A. Lind
Author: Stephen Schwarz
Author: Alan J. Auerbach
Author: Peter Harris
Author: Gianluigi Bizioli