[PDF] Elimination Of The Double Tax On Dividends eBook

Author : Marjaana Helminen
Publisher : Kluwer Law International B.V.
Page : 306 pages
File Size : 49,20 MB
Release : 2017-05-02
Category : Law
ISBN : 9041183957

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The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.

Author : Leonard E. Burman
Publisher : Brookings Institution Press
Page : 209 pages
File Size : 47,89 MB
Release : 2010-12-01
Category : Business & Economics
ISBN : 0815714955

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Few issues in tax policy are as divisive as the capital gains tax. Should capital gains--the increase in value of assets such as stocks or businesses--be taxed at all? If so, when should they be taxed--when they are earned, or when they are realized? Should taxes be adjusted for inflation? And should gains be taxed at both the individual and corporate levels? In this book, Leonard Burman cuts through the political rhetoric to present the facts about capital gains. He begins by explaining the complex rules that govern the taxation of capital gains, examines the kinds of assets that produce them, and the factors that can lead to gains or losses. He then reviews the effects of capital gains taxation on saving and investment and considers the arguments for and against indexing capital gains taxes for inflation, as well as other options for altering the current system.

Author : Randall Morck
Publisher :
Page : 66 pages
File Size : 20,57 MB
Release : 2004
Category : Dividends
ISBN :

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Arguments for eliminating the double taxation of dividends apply only to dividends paid by corporations to individuals. The double (and multiple) taxation of dividends paid by one firm to another -- intercorporate dividends - was explicitly included in the 1930s as part of a package of tax and other policies aimed at eliminating United States pyramidal business groups. These structures remain the predominant form of corporate organization outside the United States. The first Roosevelt administration associated them with corporate governance problems, corporate tax avoidance, market power, and an objectionable concentration of economic power. Future tax reforms in the United States should mind the original intent of Congress and the President regarding intercorporate dividend taxation. Foreign governments may find the American experience of value should they desire to eliminate their business groups.

Author : Randall Morck
Publisher :
Page : 45 pages
File Size : 35,49 MB
Release : 2013
Category :
ISBN :

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Arguments for eliminating the double taxation of dividends apply only to dividends paid by corporations to individuals. The double (and multiple) taxation of dividends paid by one firm to another -- intercorporate dividends - was explicitly included in the 1930s as part of a package of tax and other policies aimed at eliminating United States pyramidal business groups. These structures remain the predominant form of corporate organization outside the United States. The first Roosevelt administration associated them with corporate governance problems, corporate tax avoidance, market power, and an objectionable concentration of economic power. Future tax reforms in the United States should mind the original intent of Congress and the President regarding intercorporate dividend taxation. Foreign governments may find the American experience of value should they desire to eliminate their business groups.