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Author: Brian J Arnold
Publisher:
ISBN: 9780888082626
Category : Income accounting
Languages : en
Pages :
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Book Description
Author: Brian J Arnold
Publisher:
ISBN: 9780888082626
Category : Income accounting
Languages : en
Pages :
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Book Description
Author: Moshe Shekel
Publisher: Routledge
ISBN: 1134021941
Category : Business & Economics
Languages : en
Pages : 601
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Book Description
Time itself creates advantages and disadvantages in the field of taxation. The timing of the recognition of income and expenses for tax purposes has two main implications: firstly, for the timing of the collection of tax, and secondly, for the question of quantification, i.e., how to ensure that the difference between the timing of the recognition of income or expenses, as opposed to the respective dates on which the amounts are actually received or paid, does not distort the determination of the amount of chargeable income. The time component is a weapon in the confrontation between the opposing motivations of the taxpayers and the tax authorities. In any given fiscal year, taxpayers seek to present a minimal picture of their chargeable income, by "deferring" the recognition of income or "advancing" the recognition of expenses. As opposed to this, the tax authorities adopt the opposite strategy: maximizing taxable "profit" in any given year. This book critically examines the various approaches that have been adopted in the tax systems in the UK, the US and Israel in relation to the timing of income recognition and expenses for tax purposes. It suggests an innovative tax model that identifies the advantages that arise to the taxpayer as a result of the differences between the timing of the recognition of income and expenses, and the timing of the receipt of the revenue or the payment of a liability, and taxes only that advantage.
Author: David M. Hudson
Publisher: West Publishing Company
ISBN:
Category : Business & Economics
Languages : en
Pages : 440
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Book Description
Perspective; Gross Income; Deductions and Allowances; Timing; Who Is the Proper Taxpayer?; Characterization of Income and Deductions; Computing Tax Liability; Procedure.
Author: William D. Andrews
Publisher: Aspen Publishing
ISBN: 1543821782
Category : Law
Languages : en
Pages : 1150
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Book Description
This perennially popular book offers the most intellectual depth of any tax casebook. Regarded as the most insightful, policy-oriented, and coherent treatment of the field, Basic Federal Income Taxation includes more of the classic, foundational cases than most other tax casebooks and provides the best available coverage of capital gains. This eighth edition, the first since the death of original author William D. Andrews in 2017, aims to update a classic while preserving its distinctive attributes. The style of the book has been retained, with its focus on cases and tax policy. New to the 8th Edition: A comprehensively revised Chapter 1, designed to equip students with the conceptual framework and policy themes they can deploy to structure thinking and assist understanding throughout the course. A reworked organization, with return of capital timing issues now addressed immediately before capital appreciation (realization and recognition); gifts, taxation of the family, and assignment of income issues have been grouped together to highlight common themes; losses and tax shelter limitations have been folded into one chapter, and the leverage and leasing materials trimmed. Numerous changes to reflect new developments—legislative, administrative, and judicial—since the publication of the last edition. The pervasive influence of the Tax Cuts and Jobs Act of 2017 is reflected throughout the book. Starting with Chapter 1, this edition emphasizes the distribution of individual income tax burdens across the income spectrum, from the earned income tax credit and child tax credits to the impact of capital gain rates on high-end progressivity. Benefits for professors and students: The book was developed and refined by Professor William D. Andrews, whose work initiated serious policy analysis of progressive consumption taxes and brought to light the hybrid nature of the existing federal income tax system, which is replete with compromises between accessions and consumption tax features. When law students come to appreciate that tax is concerned with fundamental issues of distributive justice—addressing who should be required to contribute to the support of our society, and in what proportions—many become engaged by the subject in a way that would have shocked their former selves. Detailed knowledge of current tax law rules is frequently rendered obsolete (sometimes before law students can graduate) by Congress’s penchant for regular extensive amendment of the Internal Revenue Code. The book gives students a conceptual foundation that is durable rather than evanescent. Understanding tensions between the tax policy criteria and partisan differences in their evaluation makes each new round of tax Code re-jiggering, if not predictable, at least readily comprehensible. Teasing meaning out of an inordinately complex statute demands more than careful reading assisted by application of default norms of construction—it requires an appreciation of objectives. The book’s exploration of history and purposes gives students the tools necessary to inform statutory interpretation, equipping them to supply valuable practical guidance to clients and courts.
Author: Theodore S. Sims
Publisher:
ISBN:
Category :
Languages : en
Pages : 14
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Book Description
I show that the value of preferential taxation of asset returns under an income tax that extends to property income is (a) strictly increasing in the taxpayer's marginal rate if the preference takes the form of a preferential rate; but that (b) it attains some maximum at a marginal rate between 0.5 and 1 if the preference takes the form of favorable timing. Disadvantageous timing has exactly the opposite properties.
Author: Stanley I. Langbein
Publisher: Warren Gorham & Lamont
ISBN: 9780791344675
Category : Banks and banking
Languages : en
Pages :
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Book Description
Author: Daniel Q. Posin
Publisher: West Academic Publishing
ISBN:
Category : Law
Languages : en
Pages : 788
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Book Description
In clear language, Posin and Tobin's Principles of Federal Income Taxation explores exotic Wall Street techniques employed to avoid capital gains. It includes analysis of cases and concepts of the leading casebooks, explanations with amplified diagrams and flow charts, and extensive treatment of the time value of money issues. This book explains equity swaps, shorting against the box, swap funds, and DECS. It presents, among other high-profile situations, a case study of how former Treasury Secretary William Simon and his partners made $700 million in profits on the sale of the Avis car rental agency less than two years after they bought it and paid no taxes.
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: Boris I. Bittker
Publisher: Warren Gorham & Lamont
ISBN:
Category : Gifts
Languages : en
Pages : 852
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Book Description
Vol. 3 also issed as rev. 3rd ed. ; rev. 3rd edition of other vols. not planned.
Author: Mr.Victor Thuronyi
Publisher: International Monetary Fund
ISBN: 9781557755872
Category : Business & Economics
Languages : en
Pages : 534
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Book Description
Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.
