The Taxation Of Corporations And Shareholders

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The Taxation of Corporations and Shareholders

Author : Martin Norr
Publisher : Springer Science & Business Media
Page : 222 pages
File Size : 50,8 Mb
Release : 2013-06-29
Category : Business & Economics
ISBN : 9789401745024

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The Taxation of Corporations and Shareholders by Martin Norr Pdf

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.

Corporate/shareholder Income Taxation and Allocating Taxing Rights Between Countries

Author : Peter Andrew Harris
Publisher : Unknown
Page : 948 pages
File Size : 49,7 Mb
Release : 1996
Category : Aktieskatter
ISBN : UOM:35112200838391

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Corporate/shareholder Income Taxation and Allocating Taxing Rights Between Countries by Peter Andrew Harris Pdf

This ground-breaking book from the IBFD proposes a fundamental change to the norms for the allocation of taxing rights among countries. The author uses an in-depth study of imputation systems to expose the flaws in the current international order, arguing that it is theoretically unsound. He then develops an alternative that would resolve many of the problems presented by international tax law today. Imputation systems are founded on a philosophy that corporations are not appropriate subjects of income taxation, other than as vehicles for the collection of tax, & they accordingly seek to alleviate economic double taxation. In practice they do not achieve this aim. In a domestic context, considered in the first four chapters, their inconsistencies & inaccuracies obscure the more fundamental flaws of the income taxation systems of which they form a part. In an international context, considered in the second four chapters, the difficulties associated with imputation systems highlight the deficiencies in current norms for the allocation of taxing rights among countries. The author examines those norms & finds them an inadequate basis for the international order. The alternatives he proposes would place the international taxing order on a firm theoretical footing & could be applied to any type of corporate tax system. If adopted, his proposals would obviate the need for much current international tax law. Treaties, measures for the avoidance of double taxation & many anti-avoidance measures would become superfluous. This extremely important book, based on prize-winning doctoral research, is destined to become a classic in the field. The acute perception & explication of theories underpinning international taxation make it essential reading.

Taxation of Private Corporations and Their Shareholders

Author : Howard J. Kellough,Peter E. McQuillan,Canadian Tax Foundation
Publisher : Canadian Tax Foundation = Association canadienne d'études fiscales
Page : 1194 pages
File Size : 47,5 Mb
Release : 1999
Category : Corporations
ISBN : 0888081413

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Taxation of Private Corporations and Their Shareholders by Howard J. Kellough,Peter E. McQuillan,Canadian Tax Foundation Pdf

Taxation of Private Corporations and Their Shareholders

Author : Howard J. Kellough,Peter E. McQuillan
Publisher : Canadian Tax Foundation = Association canadienne d'études fiscales
Page : 1122 pages
File Size : 49,5 Mb
Release : 1992
Category : Business & Economics
ISBN : UOM:39015029288019

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Taxation of Private Corporations and Their Shareholders by Howard J. Kellough,Peter E. McQuillan Pdf

The Fundamentals of Canadian Income Tax

Author : Vern Krishna
Publisher : Carswell Legal Publications
Page : 1272 pages
File Size : 50,8 Mb
Release : 1986-01-01
Category : Law
ISBN : 0459390805

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The Fundamentals of Canadian Income Tax by Vern Krishna Pdf

Taxation of Corporations, Partnerships and Trusts

Author : Norman C. Tobias,L. Alan Rautenberg,Martin A.U. Sorensen
Publisher : Unknown
Page : 431 pages
File Size : 43,5 Mb
Release : 2017
Category : Corporations
ISBN : 0779880498

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Taxation of Corporations, Partnerships and Trusts by Norman C. Tobias,L. Alan Rautenberg,Martin A.U. Sorensen Pdf

Federal Income Taxation of Corporations and Stockholders in a Nutshell

Author : Karen C. Burke
Publisher : Unknown
Page : 0 pages
File Size : 43,5 Mb
Release : 2014
Category : Corporations
ISBN : 0314288228

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Federal Income Taxation of Corporations and Stockholders in a Nutshell by Karen C. Burke Pdf

This edition has been completely revised to reflect developments in the Code, regulations, and case law through October 2013. The text focuses on the corporation as a taxable entity and tracks the corporate life cycle from incorporation through complete liquidation. It includes discussion on nonliquidating distributions, redemptions, and stock dividends. It also addresses advanced problems in corporate taxation, such as taxable acquisitions, tax-free reorganizations and corporate divisions, and carryover of corporate tax attributes.

Anglo-American Corporate Taxation

Author : Steven A. Bank
Publisher : Cambridge University Press
Page : 128 pages
File Size : 55,5 Mb
Release : 2011-09-22
Category : Law
ISBN : 9781139502597

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Anglo-American Corporate Taxation by Steven A. Bank Pdf

The UK and the USA have historically represented opposite ends of the spectrum in their approaches to taxing corporate income. Under the British approach, corporate and shareholder income taxes have been integrated under an imputation system, with tax paid at the corporate level imputed to shareholders through a full or partial credit against dividends received. Under the American approach, by contrast, corporate and shareholder income taxes have remained separate under what is called a 'classical' system in which shareholders receive little or no relief from a second layer of taxes on dividends. Steven A. Bank explores the evolution of the corporate income tax systems in each country during the nineteenth and twentieth centuries to understand the common legal, economic, political and cultural forces that produced such divergent approaches and explains why convergence may be likely in the future as each country grapples with corporate taxation in an era of globalization.

Tax Reform Proposals

Author : United States. Congress. House. Committee on Ways and Means
Publisher : Unknown
Page : 80 pages
File Size : 40,9 Mb
Release : 1985
Category : Corporations
ISBN : PURD:32754078068982

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Tax Reform Proposals by United States. Congress. House. Committee on Ways and Means Pdf

Federal Income Taxation of S Corporations

Author : John K. McNulty
Publisher : Unknown
Page : 258 pages
File Size : 47,7 Mb
Release : 1992
Category : Business & Economics
ISBN : STANFORD:36105044538465

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Federal Income Taxation of S Corporations by John K. McNulty Pdf

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.

Examples & Explanations for Corporate Taxation

Author : Cheryl D. Block,Ari Glogower,Joshua D. Blank
Publisher : Aspen Publishing
Page : 693 pages
File Size : 46,8 Mb
Release : 2022-01-15
Category : Law
ISBN : 9781543831047

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Examples & Explanations for Corporate Taxation by Cheryl D. Block,Ari Glogower,Joshua D. Blank Pdf

A favorite classroom prep tool of successful students that is often recommended by professors, the Examples & Explanations (E&E) series provides an alternative perspective to help you understand your casebook and in-class lectures. Each E&E offers hypothetical questions complemented by detailed explanations that allow you to test your knowledge of the topics in your courses and compare your own analysis. Here’s why you need an E&E to help you study throughout the semester: Clear explanations of each class topic, in a conversational, funny style. Features hypotheticals similar to those presented in class, with corresponding analysis so you can use them during the semester to test your understanding, and again at exam time to help you review. It offers coverage that works with ALL the major casebooks, and suits any class on a given topic. The Examples & Explanations series has been ranked the most popular study aid among law students because it is equally as helpful from the first day of class through the final exam.

Taxation of Corporations and Shareholders

Author : Brian J. Arnold,D. Keith McNair,Claire Francesca Louise Young
Publisher : Carswell Legal Publications
Page : 616 pages
File Size : 48,6 Mb
Release : 1986
Category : Law
ISBN : 0459386107

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Taxation of Corporations and Shareholders by Brian J. Arnold,D. Keith McNair,Claire Francesca Louise Young Pdf