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Corporate Tax Law : Structure, Policy and Practice.
A comprehensive and comparative analysis of corporate tax systems, focusing on structural defects and how they are addressed in practice.
| Clasificación: | Libro Electrónico |
|---|---|
| Autor principal: | |
| Formato: | Electrónico eBook |
| Idioma: | Inglés |
| Publicado: |
Cambridge :
Cambridge University Press,
2013.
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| Colección: | Cambridge tax law series.
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| Temas: | |
| Acceso en línea: | Texto completo |
Tabla de Contenidos:
- Preface; Postscript; Table of cases; Table of statutes; List Of Abbreviations; General; German statutes; UK statutes; US statutes; Introduction; Approach and focus; What is a 'corporation' and why is it important?; The 'corporate tax system'; Scope and structure of the book; Chapter 1 Taxation of corporate income when derived; 1.1 Identifying and classifying corporations; 1.1.1 Identifying corporations; 1.1.1.1 Definition; Corporations; Unincorporated entities; Exclusions; Foreign entities; 1.1.1.2 Extensions; 1.1.2 Classifying corporations; 1.1.2.1 Based on relations.
- 1.1.2.2 Based on situs: resident / non-resident1.1.2.3 Based on activities: size and character; 1.1.3 Exploring relations with owners and controllers; 1.1.3.1 Nature of ownership and control; 1.1.3.2 Degrees of ownership and control; 1.1.3.3 Common ownership and control of corporations; 1.1.4 Responses to concentrated ownership and control; 1.1.4.1 Non-intervention: separate entity approach; 1.1.4.2 Erosion of identity; Collapse of separate identity: consolidation; Within a separate entity approach: transfer of tax attributes; Hybrid approaches; Problems with minority owners.
- Attribution to all ownersAttribution to controllers only; 1.1.4.3 Reinforcement of identity: independent entity approach; 1.1.5 Classifying corporations by their owners and controllers; 1.1.5.1 Controlled corporations; Control by an individual; Test of control; Attribution of rights; Control by a corporation; Test of control; Attribution of rights; Sibling corporations; Control by a single person; Control by a group of persons; 1.1.5.2 Closely held corporations; Form of threshold; Type of participation; Attribution of participations; Type of participator; Level of participation.
- Type of corporation1.1.5.3 Associated corporations; 1.2 Corporate tax base issues; 1.2.1 General rules; Schedular vs. global; Should the corporate tax base follow financial accounts?; Relationship with accounting in practice; 1.2.2 Reinforcement of corporate identity: transfer pricing; Arm's length pricing; Relevant relationship; Attribution of rights; Corresponding adjustments and subvention payments; 1.2.3 Erosion of identity: corporate groups; 1.2.3.1 Transaction deferral; Deferral mechanism; What is a group?; 1.2.3.2 Loss relief; Losses of an independent corporation.
- Use in year in which incurredCarry-back; Carry-forward; Group loss relief mechanism; Pure consolidation; Partial consolidation; Loss transfer; Group contribution; What is a group?; Minority shareholders; 1.2.3.3 Other areas; 1.2.4 Erosion of identity: other related corporations; Control by an individual; Closely held corporations; 1.2.5 Interface with personal income tax; Interface through events; Special rules for individuals: focus on simplified tax base; 1.3 Tax treatment; 1.3.1 Selecting the tax subject; Corporate taxation: in search of a philosophy; Options for tax subject.