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Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Corporations
Languages : en
Pages : 332
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Book Description
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Corporations
Languages : en
Pages : 332
Get Book Here
Book Description
Author:
Publisher:
ISBN:
Category : Corporations
Languages : en
Pages : 622
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Book Description
Author: Sydney S. Traum
Publisher: Wolters Kluwer
ISBN: 0735581517
Category : Law
Languages : en
Pages : 824
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Book Description
This quick-reference manual lets you help clients take full advantage of their S corporation status and minimize their taxes. it leads you directly to authoritative information on every aspect of the S corporation, enabling you to: Arm the S corporation against the potential tax traps hidden in the Small Business Tax Protection Act. Maximize the tax benefits of S corporation status. Make a qualified Subchapter S Subsidiary (QSub) election. Identify dispositions that will trigger the built-in gains tax. Avoid added tax liability or loss of S corporation status from passive investment income. Capitalize on the permissible differences in stock rights to facilitate estate planning and ownership transfers. Determine allocation of income, losses, and deductions in the termination year of the S corporation . Plus, there are citations To The controlling rules, regulations, and court decisions that will save you hours of research.
Author:
Publisher:
ISBN:
Category : Agricultural laborers
Languages : en
Pages : 48
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Book Description
Author: Eva Escribano
Publisher: Kluwer Law International B.V.
ISBN: 940350644X
Category : Law
Languages : en
Pages : 249
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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: Leandra Lederman
Publisher: LexisNexis
ISBN: 9781422474433
Category : Corporations
Languages : en
Pages : 0
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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:
Publisher:
ISBN:
Category : Income tax
Languages : en
Pages : 12
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Author:
Publisher:
ISBN:
Category : Corporations
Languages : en
Pages : 128
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Book Description
Author:
Publisher:
ISBN:
Category : Corporations
Languages : en
Pages : 206
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Book Description
Author:
Publisher:
ISBN:
Category : Corporations
Languages : en
Pages : 982
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Book Description
