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Author: Miguel Correia Publisher: ISBN: 9789041148414 Category : Corporations Languages : en Pages : 0
Book Description
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.
Author: Miguel Correia Publisher: ISBN: 9789041148414 Category : Corporations Languages : en Pages : 0
Book Description
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.
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: John K. McNulty Publisher: ISBN: Category : Business & Economics Languages : en Pages : 258
Book Description
Provides introductory explanation of the purposes and uses of the federal income tax law relating to S corporations. Topics include acquiring and maintaining the S status, tax issues and consequences, effects of the S election to shareholders, and tax-free reorganizations and divisions of S corporations, as well as comparisons to C corporations and partnerships.
Author: Guglielmo Maisto (jurist.) Publisher: IBFD ISBN: 9087220286 Category : Corporations Languages : en Pages : 593
Book Description
Comprising the proceedings and working documents of an annual seminar held in Milan in November 2007, this book analyses the tax issues for groups of companies operating in a European or worldwide dimension. The book examines the issues raised by both tax treaty and European law by focusing on selected topics. It first provides an analysis of the group concept under company and commercial law followed by an overview of taxation of groups in common and civil law countries. The tax regime of groups of companies under European law is further considered, both for income tax and VAT. The issues raised by application of tax treaties to groups of companies is then considered, with a particular emphasis on treaty recognition of groups, application of tax treaties to companies included in national group consolidation regimes, and application of the treaty articles on business income and non-discrimination. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and North American jurisdictions.
Author: Martin Norr Publisher: Springer Science & Business Media ISBN: 9401745021 Category : Business & Economics Languages : en Pages : 222
Book Description
This monograph is principally the work of the late Martin Norr. He completed a draft of the entire monograph but had not yet revised it when he died in late 1972. At that time, the integration of corporate and shareholder taxation was just beginning to become of widespread interest in the United States. With the increasing interest thereafter, the International Tax Program began to revise his manuscript, making as few changes as possible in the original draft. We had the benefit of criticism and analysis from Professor Richard M. Bird of the University of Toronto, now Director of the Institute of Policy Analysis there. In addition, Mr. Mitsuo Sato of the Ministry of Finance in Japan gave freely of his time in carefully suggesting changes throughout the manuscript. The present version of Chapter 3 owes a great deal to his additions and suggestions. Thanks are also due to Professor Hugh J. Ault of Boston College Law School for the Appendix, containing his description of the German integration system that became effective in 1977, which was first published in Law & Policy in International Business. Mr. Norr's interest in the subject of corporate and shareholder taxation developed while he was writing the International Tax Program's World Tax Series volume Taxation in France, published in 1966. The integration of French taxes on corporations and shareholders took place just after that volume was finished, but had been under discussion in France for some time before then.
Author: Miguel Correia
Author: Miguel Correia
Author: Antony Ting
Author: Miguel G. Correia
Author: Miguel G. Correia
Author: 
Author: Eva Escribano
Author: John K. McNulty
Author: Guglielmo Maisto (jurist.)
Author: United States. General Accounting Office
Author: Martin Norr