Federal Taxation of Corporations and Corporate Transactions PDF Download
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Author: Steven Dean
Publisher: Aspen Publishing
ISBN: 1454895446
Category : Law
Languages : en
Pages : 94
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Book Description
This client file (based on a hypothetical launch of an Internet of Things business, called Digital Widgets) complements the foundational materials contained in Federal Taxation of Corporations and Corporate Transactions by Steven Dean and Brad Borden, by providing students with an opportunity to apply and deepen their knowledge of corporate tax law. It contains a set of memoranda setting out problems for students to analyze and present client advice on, utilizing the materials contained in the casebook.
Author: Steven Dean
Publisher: Aspen Publishing
ISBN: 1454895446
Category : Law
Languages : en
Pages : 94
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Book Description
This client file (based on a hypothetical launch of an Internet of Things business, called Digital Widgets) complements the foundational materials contained in Federal Taxation of Corporations and Corporate Transactions by Steven Dean and Brad Borden, by providing students with an opportunity to apply and deepen their knowledge of corporate tax law. It contains a set of memoranda setting out problems for students to analyze and present client advice on, utilizing the materials contained in the casebook.
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: Michael Feeney
Publisher: Bloomsbury Publishing
ISBN: 1784514527
Category : Business & Economics
Languages : en
Pages : 2469
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Book Description
This key book provides the most comprehensive analysis and commentary available on the taxation of companies in Ireland.This new edition is updated to the latest Finance Act. An extremely practical book, it features detailed worked examples and extensive references to case law throughout the work. The guidance and advice outlines how to successfully apply the new tax reliefs, keeping your clients' tax liabilities as low as possible.ContentsChapter 1 Introduction & OutlineChapter 2 InterpretationChapter 3 Charge to Corporation TaxChapter 4 Losses, Collection of Tax at Source and Charges on IncomeChapter 5 Capital AllowancesChapter 6 Transfer PricingChapter 7 Corporation Tax Incentive ReliefsChapter 8 Group ReliefChapter 9 Companies' Capital Gains and Company ReconstructionsChapter 10 Close CompaniesChapter 11 Distributions, Buy-back of SharesChapter 12 Special Types of CompaniesChapter 13 Special Types of BusinessChapter 14 Double Taxation ReliefChapter 15 Self-Assessment and Administration
Author: Alan Moore
Publisher: Tax World Ltd
ISBN: 1902065190
Category : Business & Economics
Languages : es
Pages : 163
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Book Description
Finance Act 2017 - The Irish tax law updates for the year 2017
Author: David J. Cartano
Publisher:
ISBN: 9780808044239
Category : Business & Economics
Languages : en
Pages : 0
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Book Description
Federal and State Taxation of Limited Liability Companies provides clear and reliable guidance on what the latest tax treatment is for limited liability companies and what it means for your clients or your business. This hands-on treatise is dedicated entirely to the taxation of LLCs. It answers all of your questions with an analysis of all federal tax issues applicable to LLCs with detailed references to related Code Sections and Treasury Regulations, plus cases, revenue rulings and private letter rulings. It provides a state-by-state analysis of state tax laws and filing requirements in all 50 states and the District of Columbia, with references to the applicable tax forms and places of filing listed. It explains how to prepare the most common LLC tax forms, state tax forms, checklists, practice tips, tables, and examples. This comprehensive manual offers scrupulous and exhaustive coverage of LLC taxation that accountants, tax attorneys, and CPAs working with LLCs will find invaluable for daily reference.
Author: Congressional Service
Publisher: Createspace Independent Publishing Platform
ISBN: 9781720533115
Category :
Languages : en
Pages : 48
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Book Description
One of the major motivations for the 2017 tax revision (P.L. 115-97) was concern about the international tax system. Issues associated with these rules involved the allocation of investment between the United States and other countries, the loss of revenue due to the artificial shifting of profit out of the United States by multinational firms (both U.S. and foreign), the penalties for repatriating income earned by foreign subsidiaries that led to the accumulation of deferred earnings abroad, and inversions (U.S. firms shifting their headquarters to other countries for tax reasons). In addition to lowering the corporate tax rate from 35% to 21% and providing some other benefits for domestic investment (such as temporary expensing of equipment), the 2017 tax bill also substantially changed the international tax regime. The tax change moved the system from a nominal worldwide tax on all foreign-source income, with a credit against U.S. tax for foreign taxes due, to a nominal territorial system that does not tax foreign-source income. Nevertheless, both systems could be considered a hybrid of a worldwide and territorial system. Prior law reduced the tax on foreign-source income by allowing deferral (taxing income of foreign subsidiaries only if it was repatriated, or paid as a dividend to the U.S. parent) and cross-crediting of foreign taxes (so the credit for high taxes paid in one country could offset U.S. tax on income from a low-tax country). The new system exempts dividends, but also imposes a current worldwide tax on global intangible low-taxed income (GILTI), but at a lower rate. It also introduces a corresponding lower rate on intangible income derived from abroad from assets in the United States (foreign-derived intangible income, or FDII). The new law adds the base erosion and anti-abuse tax (BEAT) to existing anti-abuse measures aimed at artificial profit shifting. BEAT imposes a minimum tax on ordinary income plus certain payments to related foreign companies. Despite the lower corporate tax rate, it is not clear that capital will be shifted into the United States from abroad; although a lower rate reduces the tax rate on equity-financed investments, it decreases the subsidy to debt-financed investments. Whether the capital stock increases or decreases depends on the magnitude of the tax changes (which appear largely offsetting) and the international mobility of debt versus equity. It is also not clear whether the capital stock will be allocated more efficiently or in a way more optimal for U.S. welfare, although economic theory suggests that reducing the tax subsidy for debt is a clear improvement. Although a territorial tax may make profit shifting more attractive, overall, given other elements of the new system, it appears to make profit shifting less important. GILTI and FDII bring the tax treatment of income from intangibles in the United States and abroad closer together, and BEAT and stricter thin capitalization rules (rules limiting interest deductions) also limit profit shifting, including shifting through leveraging. The new system ends the penalties (except for portfolio investment in foreign firms) for repatriating earnings and thus eliminates the prior incentives to retain earnings abroad. A series of measures aimed at inversions appears to make inversions much less attractive. Some of the measures may violate international agreements such as the World Trade Organization (WTO), bilateral tax treaties, and Organization for Economic Cooperation and Development (OECD) minimum standards to prevent harmful tax practices. There have been a number of concerns about design features in the new regime, including the dividend deduction, GILTI, FDII, BEAT, and other features. A variety of options might be considered to address these issues.
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Corporations
Languages : en
Pages : 256
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Book Description
Author: OECD
Publisher: OECD Publishing
ISBN: 9264287957
Category :
Languages : en
Pages : 658
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Book Description
This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
Author: OECD
Publisher: OECD Publishing
ISBN: 9264265120
Category :
Languages : en
Pages : 612
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Book Description
This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.
Author: Robert F. van Brederode
Publisher:
ISBN: 9789041184733
Category : Corporations
Languages : en
Pages : 0
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Book Description
Legal Interpretation of Tax Law' is a comprehensive multi-jurisdiction survey of the interpretation of the corporate income tax and VAT and GST or other general sales tax laws. As a result of the globalization of trade and business, tax departments and their external advisors are increasingly required to deal with the tax law of foreign jurisdictions. Effective consulting, whether internal or external, requires not only knowledge of tax law per se but also of how tax law is explained and interpreted by the courts of foreign jurisdictions. This book is the first to deal comparatively with tax law interpretation in economies engaged in cross-border investment at a global level.00The introduction outlines the theoretical approaches to legal interpretation in general and gives an overview of issues and topics relevant to taxation ? designed to help readers understand the jurisdictional chapters that follow. Each author pays detailed attention to such documentary elements as explanatory memoranda, administrative rulings, judicial precedents, judgments of foreign courts, legislative debates, and OECD guidelines.
