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Author : United States. Department of the Treasury
Publisher : Unknown
Page : 52 pages
File Size : 41,9 Mb
Release : 1979
Category : Government publications
ISBN : PURD:32754078702457
Author : Ms.Thornton Matheson,Victoria J. Perry,Mr.Chandara Veung
Publisher : International Monetary Fund
Page : 26 pages
File Size : 52,7 Mb
Release : 2013-10-03
Category : Business & Economics
ISBN : 9781484398463
Global investment patterns mean that effective taxation of foreign investors is of increasing importance to the economies of lower income countries. It is thus of considerable concern that the historical framework for cross-border income tax arrangements is not always well suited to allow low-income countries (LICs) effectively to generate tax revenues from profits on foreign direct investment (FDI). Several aspects of this framework contribute to the problem. This paper discusses, in particular, the likely effect of a shift by major economies from the system of worldwide corporate taxation toward a territorial system on the volume, distribution, and financing of FDI, focusing on LICs. It then empirically analyzes bilateral outbound FDI data for the UK for 2002–10 to determine whether the move to territoriality made corporations more sensitive to hostcountry statutory tax rates. Supporting evidence for this hypothesis is found for FDI financed from new equity.
Author : Jane Gravelle
Publisher : Createspace Independent Publishing Platform
Page : 0 pages
File Size : 52,8 Mb
Release : 2012-08-02
Category : Political Science
ISBN : 147835559X
Among potential tax reforms under discussion by Congress is revising the tax treatment of foreign source income of U.S. multinational corporations. Some business leaders have been urging a movement toward a territorial tax, which would eliminate some U.S. income taxes on active foreign source income. Under a territorial tax, only the country where the income is earned imposes a tax. Territorial proposals include the Grubert-Mutti proposal (included in President Bush's Advisory Panel on Tax Reform proposal in 2005) and, more recently, a draft Ways and Means Committee proposal and a Senate bill, S. 2091. The Fiscal Commission also proposed a territorial tax. Proposals have, however, also been made to increase the taxation of foreign source income, including S. 727, and proposals by President Obama. Although the United States has a worldwide system that includes foreign earnings in U.S. taxable income, two provisions cause the current system to resemble a territorial tax in that very little tax is collected. Deferral delays paying taxes until income is repatriated (paid as a dividend by the foreign subsidiary to its U.S. parent). When income is repatriated, credits for foreign taxes paid offset the U.S. tax due. Under cross-crediting, unused foreign tax credits from high tax countries or on highly taxed income can be used to offset U.S. tax on income in low tax countries. Some proponents of a territorial tax urge such a system on the grounds that the current system discourages repatriations. Economic evidence suggests that effect is small, in part because in normal circumstances a large share of income is retained for permanent reinvestment. Amounts held abroad may have increased, however, as firms lobbied for another repatriation holiday (similar to that adopted in 2004) that allowed firms to exempt most dividends from income on a one-time basis. Opponents are concerned about encouraging investment abroad. A territorial tax is generally not viewed as efficient because it favors foreign investment, but that increased outflow of investment is likely to have a small effect relative to the U.S. economy. Artificial shifting of profits into tax havens or low tax countries is a current problem that could be worsened under some territorial tax designs, and proposals have included measures to address this problem. Proposals also address the transitional issue of the treatment of the existing stock of unrepatriated earnings. The Ways and Means proposal would tax this stock of earnings, but at a lower rate, and use the revenues to offset losses from other parts of the plan, which would lead to a long-run revenue loss. S. 2091 has a similar approach. The Grubert-Mutti proposal does not have a specific transitional tax, but would raise revenue largely due to its disallowance of parent overhead expenses aimed at reducing profit shifting. The other two proposals also contain provisions to address profit shifting. In addition there are complicated issues in the design of a territorial tax, such as how to treat branches and dividends of firms in which the corporation is only partially owned. A number of issues arise from the ending of foreign tax credits, with perhaps the most significant one being the increased tax on royalties, which are currently subject to tax, have low or no foreign taxes, and would lose the shield of excess credits. The final section of the report briefly discusses some alternative options, including those in S.727 and in the Administration proposals. It also discusses hybrid approaches that combine territorial and worldwide systems in a more efficient way, including eliminating the disincentive to repatriate. One such approach is a minimum tax on foreign source income, which is proposed by the President in the context of current rules, but could be combined with a territorial system.
Author : OECD
Publisher : OECD Publishing
Page : 100 pages
File Size : 50,9 Mb
Release : 2017-07-27
Category : Electronic
ISBN : 9789264278790
This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).
Author : Mark P. Keightley,Molly F. Sherlock
Publisher : Createspace Independent Publishing Platform
Page : 0 pages
File Size : 54,5 Mb
Release : 2012-10-22
Category : Business & Economics
ISBN : 1480166618
Many economists and policymakers believe that the U.S. corporate tax system is in need of reform. There is, however, disagreement over why the corporate tax system needs to be reformed, and what specific policy measures should be included in a reform. To assist policymakers in designing and evaluating corporate tax proposals, this report (1) briefly reviews the current U.S. corporate tax system; (2) discusses economic factors that may be considered in the corporate tax reform debate; and (3) presents corporate tax reform policy options, including a brief discussion of current corporate tax reform proposals. The current U.S. corporate income tax system generally taxes corporate income at a rate of 35%. This tax is applied to income earned domestically and abroad, although taxes on certain income earned abroad can be deferred indefinitely if that income remains overseas. The U.S. corporate tax system also contains a number of deductions, exemptions, deferrals, and tax credits, often referred to as "tax expenditures." Collectively, these provisions reduce the effective tax rate paid by many U.S. corporations below the 35% statutory rate. In 2011, the sum of all corporate tax expenditures was $158.8 billion. The significance of the corporate tax as a federal revenue source has declined over time. At its post-WWII peak in 1952, the corporate tax generated 32.1% of all federal tax revenue. In 2010, the corporate tax accounted for 8.9% of federal tax revenue. The decline in corporate revenues is a combination of decreasing effective tax rates, an increasing fraction of business activity that is being carried out by pass-through entities (particularly partnerships and S corporations, which are not subject to the corporate tax), and a decline in corporate sector profitability. A particular aspect of the corporate tax system that receives substantial attention is the 35% statutory corporate tax rate. Although the U.S. has the world's highest statutory corporate tax rate, the U.S. effective corporate tax rate is similar to the Organization for Economic Co-operation and Development (OECD) average. Further, the U.S. collects less in corporate tax revenue relative to Gross Domestic Production (GDP) (1.9% in 2009) than the average of other OECD countries (2.8% in 2009). This report discusses a number of economic considerations that may be made while evaluating various corporate tax reform proposals. These might include analyses of the likely effect on households of certain reforms (also known as incidence analysis). Policymakers might also want to consider how certain corporate tax provisions contribute to the allocation of economic resources, choosing policies that promote an efficient use of resources. Other goals of corporate tax reform may include designing a system that is simple to comply with and administer, while also promoting competitiveness of U.S. corporations. Commonly discussed corporate tax reforms include policies that would broaden the tax base (i.e., eliminate tax expenditures) to finance reduced corporate tax rates. Concerns that the U.S. corporate tax system inefficiently imposes a "double tax" on corporate income has led some to consider an integration of the corporate and individual tax systems. The treatment of pass-through income-business income not earned by C corporations-has also received considerable attention in tax reform debates. How the U.S. taxes income earned abroad, and the possibility of moving to a territorial tax system, have emerged as important issues. Both the Obama Administration and the House Committee on Ways and Means Chairman David Camp have released tax reform proposals that would change the current tax treatment of U.S. multinationals.
Author : Ms.Li Liu
Publisher : International Monetary Fund
Page : 49 pages
File Size : 44,7 Mb
Release : 2018-01-12
Category : Business & Economics
ISBN : 9781484337493
In 2009, the United Kingdom changed from a worldwide to a territorial tax system, abolishing dividend taxes on foreign repatriation from many low-tax countries. This paper assesses the causal effect of territorial taxation on real investments, using a unique dataset for multinational affiliates in 27 European countries and employing the difference-in-difference approach. It finds that the territorial reform has increased the investment rate of UK multinationals by 15.7 percentage points in low-tax countries. In the absence of any significant investment reduction elsewhere, the findings represent a likely increase in total outbound investment by UK multinationals.
Author : Congressional Research Congressional Research Service
Publisher : CreateSpace
Page : 38 pages
File Size : 43,9 Mb
Release : 2014-12-01
Category : Electronic
ISBN : 1505450071
Many economists and policy makers believe that the U.S. corporate tax system is in need of reform. There is, however, disagreement over why the corporate tax system needs to be reformed, and what specific policy measures should be included in a reform. To assist policy makers in designing and evaluating corporate tax proposals, this report (1) briefly reviews the current U.S. corporate tax system; (2) discusses economic factors that may be considered in the corporate tax reform debate; and (3) presents corporate tax reform policy options, including a brief discussion of current corporate tax reform proposals. The current U.S. corporate income tax system generally taxes corporate income at a rate of 35%. This tax is applied to income earned domestically and abroad, although taxes on certain income earned abroad can be deferred indefinitely if that income remains overseas. The U.S. corporate tax system also contains a number of deductions, exemptions, deferrals, and tax credits, often referred to as "tax expenditures." Collectively, these provisions reduce the effective tax rate paid by many U.S. corporations below the 35% statutory rate. In 2014, the sum of all corporate tax expenditures was $154.4 billion. The significance of the corporate tax as a federal revenue source has declined over time. At its post-WWII peak in 1952, the corporate tax generated 32.1% of all federal tax revenue. In 2013, the corporate tax accounted for 9.9% of federal tax revenue. The decline in corporate revenues is a combination of decreasing effective tax rates, an increasing fraction of business activity that is being carried out by pass-through entities (particularly partnerships and S corporations, which are not subject to the corporate tax), and a decline in corporate sector profitability. A particular aspect of the corporate tax system that receives substantial attention is the 35% statutory corporate tax rate. Although the United States has the world's highest statutory corporate tax rate, the U.S. effective corporate tax rate is similar to the Organization for Economic Co-operation and Development (OECD) average. Further, the United States collects less in corporate tax revenue relative to Gross Domestic Production (GDP) (2.3% in 2011) than the average of other OECD countries (3.0% in 2011). This report discusses a number of economic considerations that may be made while evaluating various corporate tax reform proposals. These might include analyses of the likely effect on households of certain reforms (also known as incidence analysis). Policy makers might also want to consider how certain corporate tax provisions contribute to the allocation of economic resources, choosing policies that promote an efficient use of resources. Other goals of corporate tax reform may include designing a system that is simple to comply with and administer, while also promoting competitiveness of U.S. corporations. Commonly discussed corporate tax reforms include policies that would broaden the tax base (i.e., eliminate tax expenditures) to finance reduced corporate tax rates. Concerns that the U.S. corporate tax system inefficiently imposes a "double tax" on corporate income have led some to consider an integration of the corporate and individual tax systems. The treatment of pass-through income-business income not earned by C corporations-has also received considerable attention in tax reform debates. How the United States taxes income earned abroad, and the possibility of moving to a territorial tax system, have emerged as important issues.
Author : Michael Littlewood
Publisher : Hong Kong University Press
Page : 375 pages
File Size : 40,6 Mb
Release : 2010-01-01
Category : Business & Economics
ISBN : 9789622090996
This book tells an instructive tale of Hong Kong's tax system from 1940 (when taxes on income were first introduced in the territory) until the present day. For Hong Kong's own historians and political scientists, it supplies cogent but previously neglected evidence of the influence of the territory's business interests. For students of British imperialism, it provides a compelling case-study of relations between London and a recalcitrant colony. For Hong Kong's own tax profession, it corrects the notion that the territory's tax system was the product of governmental design. And for tax theorists and taxpayers everywhere, it suggests how it might be possible to structure a combination of very light taxes and very low public spending so as to win broad popular support.--Michael Littlewood is a member of the Faculty of Law at the University of Auckland, where he teaches tax. His work has been published in the U.S., the U.K., Hong Kong, China, the Netherlands, Australia and New Zealand. He lived in Hong Kong from 1989 until 2003.--"An excellent read ... partly a matter of 'who done it?' but, even more so, of 'how did they get away with it?' Dr. Littlewood's book will prove indispensable for anyone wanting to use the Hong Kong precedent to argue for a flat rate tax system in their own country." - John Tiley, Professor of Tax Law, University of Cambridge--"Fascinating ... [This book is] a first-rate history and raises troubling questions about the necessity of linking taxes and democratic choice. The book also raises intriguing doubts about whether low taxes and low services may be an acceptable alternative model to the prevalent high-tax, high-services Western welfare state. This book should be required reading for students of political science, history, sociology and law." - Reuven Avi-Yonah, Irwin I. Kohn Professor of Law, University of Michigan-----
Author : Jane G. Gravelle
Publisher : DIANE Publishing
Page : 24 pages
File Size : 51,7 Mb
Release : 2011-04
Category : Reference
ISBN : 9781437980899
Is the current U.S. tax system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its basic structure be reformed? Contents of this report: The Current System and Possible Revisions; Neutrality, Efficiency, and Competitiveness; Assessing the Existing Tax System; Territorial Taxation: The Dividend Exemption Proposal; A Residence-Based System in Practice; President Obama's Proposals to Restrict Deferral and Cross-Crediting; Tax Havens: Issues and Policy Options; General Reforms of the Corporate Tax and Implications for International Tax Treatment. Charts and tables. This is a print on demand edition of an important, hard-to-find publication.
Author : Charlotte Ecton,Sam Hamlin
Publisher : Nova Science Publishers
Page : 0 pages
File Size : 54,5 Mb
Release : 2013
Category : Corporations
ISBN : 162257978X
Tax reform is a perennial issue before Congress. One area of increasing attention is the taxation of U.S. companies on the income they earn abroad. Business leaders have been urging a movement toward a territorial tax, which would generally eliminate U.S. income taxes on active foreign source income. Tax on the income of foreign subsidiaries is deferred until repatriated and tax can be avoided by not repatriating income. Economists have traditionally analysed the foreign tax system in terms of economic efficiency. Economic theory tends to support, on efficiency grounds, a world-wide system in which income from U.S. investment earned abroad is subject to the same tax, or as close to the same tax as possible, as that on domestic investment. This book provides an overview of how the international tax system works and describes the magnitude and distribution of foreign source income and taxes, with a focus on the alternative features of a territorial tax and their consequences.
Author : Anonim
Publisher : Unknown
Page : 12 pages
File Size : 44,7 Mb
Release : 1988
Category : Income tax
ISBN : MINN:31951D013914451
Author : PriceWaterhouseCoopers LLP
Publisher : Capstone
Page : 966 pages
File Size : 45,5 Mb
Release : 2003-07-10
Category : Business & Economics
ISBN : UCSC:32106017857480
Large international corporations and accountants representing international interests require the most up-to-date information regarding tax issues in countries around the world. Corporate Taxes 2003-2004 provides vital information on the corporate implications of the tax systems of over 120 countries.
Author : Myron S. Scholes,Mark A. Wolfson,Merle M. Erickson,Michelle L. Hanlon,Edward L. Maydew,Terrence J. Shevlin
Publisher : Unknown
Page : 528 pages
File Size : 47,5 Mb
Release : 2015-01-03
Category : Electronic
ISBN : 1292065575
For MBA students and graduates embarking on careers in investment banking, corporate finance, strategy consulting, money management, or venture capital Through integration with traditional MBA topics, Taxes and Business Strategy, Fifth Edition provides a framework for understanding how taxes affect decision-making, asset prices, equilibrium returns, and the financial and operational structure of firms. Teaching and Learning Experience This program presents a better teaching and learning experience-for you and your students: *Use a text from an active author team: All 5 authors actively teach the tax and business strategy course and provide students with relevant examples from both classroom and real-world consulting experience. *Teach students the practical uses for business strategy: Students learn important concepts that can be applied to their own lives. *Reinforce learning by using in-depth analysis: Analysis and explanatory material help students understand, think about, and retain information.
Author : Jason Clemens
Publisher : The Fraser Institute
Page : 208 pages
File Size : 43,9 Mb
Release : 2008
Category : Fiscal policy
ISBN : 9780889752290
"There is increasing interest in, and recognition of, the need for both tax reduction and tax reform in Canada. This book provides the rationale for tax reform and a road map for that reform. The book includes 5 chapters from leading experts in the field and provides a persuasive, compelling case for tax reform in Canada." "The Impact of Taxes on Economic Behavior by Milagros Palacios and Kumi Harischandra offers a broad overview of the incentive effects associated with taxes that affect our decisions to work more, to save, to invest, and to engage in entrepreneurial activity." "Compliance and Administrative Costs of Taxation in Canada by renowned University of Montreal economics professor Francois Vaillancourt and Jason Clemens provides readers with an understanding of the vast costs associated with administering, and complying with, our current tax system."--BOOK JACKET.
Author : OECD
Publisher : OECD Publishing
Page : 82 pages
File Size : 42,6 Mb
Release : 1998-05-19
Category : Electronic
ISBN : 9789264162945
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.