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The Double Taxation Of Dividend Income
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Author :Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation Publisher : ISBN 13 : Total Pages :16 pages Book Rating :4.A/5 ( download)
Book Synopsis The Double Taxation of Dividend Income by : Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation
Download or read book The Double Taxation of Dividend Income written by Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation and published by . This book was released on 1953 with total page 16 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation Publisher : ISBN 13 : Total Pages :4 pages Book Rating :4.:/5 (119 download)
Book Synopsis The Double Taxation of Dividend Income by : Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation
Download or read book The Double Taxation of Dividend Income written by Chamber of Commerce of the United States of America. Finance Department. Committee on Taxation and published by . This book was released on 1953 with total page 4 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :Chamber of Commerce of the United States of America. Taxation, Committee on Publisher : ISBN 13 : Total Pages :4 pages Book Rating :4.:/5 (113 download)
Book Synopsis The Double Taxation of Dividend Income by : Chamber of Commerce of the United States of America. Taxation, Committee on
Download or read book The Double Taxation of Dividend Income written by Chamber of Commerce of the United States of America. Taxation, Committee on and published by . This book was released on 1953 with total page 4 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of Intercompany Dividends Under Tax Treaties and EU Law by : Guglielmo Maisto
Download or read book Taxation of Intercompany Dividends Under Tax Treaties and EU Law written by Guglielmo Maisto and published by IBFD. This book was released on 2012 with total page 1093 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
Book Synopsis Elimination of the Double Tax on Dividends by : American Institute of Certified Public Accountants
Download or read book Elimination of the Double Tax on Dividends written by American Institute of Certified Public Accountants and published by . This book was released on 1976 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective by : Erwin Nijkeuter
Download or read book Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective written by Erwin Nijkeuter and published by Kluwer Law International B.V.. This book was released on 2012-08-01 with total page 168 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is the first in-depth study to analyze the circumstances in which the freedom of establishment or free movement of capital may apply to the cross-border distribution of dividends. It covers both the positive integration set forth by the European Commission and the Member States and the negative integration developed by the European Court of Justice. The author discusses such elements of these integration measures as the following: economic double taxation (two different subjects pay tax on the same profit); juridical double taxation (two different states tax one and the same person for the same income); exemption, credit, and other techniques adopted by States to avoid double taxation; division of taxing rights between two States with respect to dividend income; prevention of juridical double taxation by bilateral tax conventions; Member States’ mitigation of economic double taxation; double exemption as an unplanned outcome of double taxation prevention measures; and order of precedence between freedom of establishment and free movement of capital. The analysis treats relevant provisions the OECD Model Tax Convention in detail, as this model is widely used by national tax authorities in connection with international taxation of dividends. It also examines pertinent initiatives launched by the European Commission up to and including its consultation paper of January 28, 2011. In addition to its scrutiny of the disparities in cross-border dividend taxation within the European Union, this book stands out for its detailed coverage of the progress made in resolving these challenging taxation issues. It is sure to be welcomed by investors, corporate counsel, and national revenue authorities.
Book Synopsis The International Tax Law Concept of Dividend by : Marjaana Helminen
Download or read book The International Tax Law Concept of Dividend written by Marjaana Helminen and published by Kluwer Law International B.V.. This book was released on 2017-05-02 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Rethinking Double Taxation's Role in Dividend Policy by : Steven A. Bank
Download or read book Rethinking Double Taxation's Role in Dividend Policy written by Steven A. Bank and published by . This book was released on 2003 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: Corporate dividend policy has long been a source of concern in both tax and corporate law. From a tax law perspective, retained earnings potentially escape the high marginal rates imposed on shareholders. From a corporate law perspective, retained earnings increase agency costs for shareholders. With the steady drop in dividends in the last decade, concern over dividend policy has arisen once again. Many commentators attribute the disappearance of the dividend to our corporate income tax system, which quot;trapsquot; retained earnings in the corporation by subjecting dividends to two layers of tax. The assumption is that integrating the corporate and shareholders income taxes - either through a dividend exemption or some other technique - will lead corporations to pay out more money as dividends.Missing from this analysis is any historical perspective on the relationship between taxation and corporate dividend policies. The double taxation of corporate income actually emerged between World War I and II in response to a shift in corporate dividend policies, rather than vice versa. Over that period, managers agreed to a higher rate of tax at the corporate level, and, eventually, to the repeal of the dividend exemption at the shareholder level in exchange for Congress' tacit agreement not to interfere with managerial discretion over undistributed profits. This history not only belies the claim that double taxation is responsible for the disappearance of the dividend, but also suggests that integration of the corporate and shareholder income taxes may not have the effect on corporate dividend policies that its proponents claim.
Book Synopsis The Dividend Concept in International Tax Law:Dividend Payments Between Corporate Entities by : Marjaana Helminen
Download or read book The Dividend Concept in International Tax Law:Dividend Payments Between Corporate Entities written by Marjaana Helminen and published by Springer. This book was released on 1999-12-09 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The distribution of profits between corporations resident in different jurisdictions gives rise to significant tax planning opportunities for multinational enterprises. 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. This unique and practical work covers the rules determining which transactions may be classified and therefore taxed as dividend income and how classification conflicts may be resolved. The author examines the 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 capitalisation situations and distributions following liquidation The analysis of each transaction refers to international tax law, including tax treaties, European tax law and the domestic tax law of Finland, Germany, Sweden and the United States. The comprehensive coverage and practical nature of The Dividend Concept in International Tax Law make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Book Synopsis International Double Taxation by : United States. Congress. House. Committee on Ways and Means
Download or read book International Double Taxation written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1930 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States by : International Monetary Fund
Download or read book Possible Implications of Integrating the Corporate and Individual Income Taxes in the United States written by International Monetary Fund and published by International Monetary Fund. This book was released on 1990-07-01 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: The classical corporate profits tax in the United States involves non-neutralities between: different sources of financing; different forms of business organization; and retaining or distributing earnings and may result in the U.S. investor being at a disadvantage vis-à-vis foreign investors. An international comparison is provided, and the potential effects of different integration schemes on the user cost of capital and tax revenues are assessed. The integration of corporate and individual income taxes in the United States could lead to a more efficient domestic and worldwide allocation of resources.
Book Synopsis The Story of Double Taxation by : Steven A. Bank
Download or read book The Story of Double Taxation written by Steven A. Bank and published by . This book was released on 2005 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This chapter examines the circumstances leading up to repeal of the dividend exemption and the introduction of full double taxation. In the Revenue Act of 1936, President Roosevelt introduced a radical plan to combat corporate hoarding of earnings by replacing the corporate income tax with an undistributed profits tax and a repeal of the dividend exemption. If distributed as dividends, corporate income would only be subject to the individual income tax. If retained, however, corporate income would be subject to both a punitive undistributed profits tax and, upon distribution in later years, the individual income tax as well. In the face of opposition from managers and concerns about revenue if the corporate income tax was abandoned, Congress settled on a compromise. It adopted a more modest version of Roosevelt's plan for an undistributed profits tax while retaining the corporate income tax. No effort was made, though, to restore the dividend exemption. Thus, for the first time corporate earnings were fully subject to both the corporate and individual income taxes. This tax on dividends survived the repeal of the undistributed profits tax a few years later.Some have called the introduction of double taxation under the circumstances of the Revenue Act of 1936 inadvertent or a case of business talk[ing] itself into a higher tax bill. The story, however, is much more complicated than that, involving a clash over the control of corporate earnings. As this chapter will explain, the threat posed to managers by the undistributed profits tax led to the retention of the corporate income tax and the repeal of the dividend exemption. Far from being a typical New Deal assault on big business or an inadvertent by-product of the compromise over Roosevelt's original proposal, double taxation was a pro-manager measure adopted to blunt the force of the undistributed profits tax. Business leaders and their allies in Congress hoped that the repeal of the dividend exemption and the resulting imposition of double taxation would aid in aligning management-shareholder attitudes toward the retention of corporate earnings. Double taxation thus became a tool in the campaign against the undistributed profits tax.This paper will be published as a chapter in a book entitled Business Tax Stories, to be published by Foundation Press later this year (2005).
Book Synopsis The Labyrinth of Capital Gains Tax Policy by : Leonard E. Burman
Download or read book The Labyrinth of Capital Gains Tax Policy written by Leonard E. Burman and published by Brookings Institution Press. This book was released on 2010-12-01 with total page 209 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Double Taxation in the United States by : Francis Walker
Download or read book Double Taxation in the United States written by Francis Walker and published by . This book was released on 1895 with total page 138 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis How to Eliminate Pyramidal Business Groups by : Randall Morck
Download or read book How to Eliminate Pyramidal Business Groups written by Randall Morck and published by . This book was released on 2004 with total page 66 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Double Dividend by : Dale W. Jorgenson
Download or read book Double Dividend written by Dale W. Jorgenson and published by MIT Press. This book was released on 2013-11-29 with total page 639 pages. Available in PDF, EPUB and Kindle. Book excerpt: A rigorous and innovative approach for integrating environmental policies and fiscal reform for the U.S. economy. Energy utilization, especially from fossil fuels, creates hidden costs in the form of pollution and environmental damages. The costs are well documented but are hidden in the sense that they occur outside the market, are not reflected in market prices, and are not taken into account by energy users. Double Dividend presents a novel method for designing environmental taxes that correct market prices so that they reflect the true cost of energy. The resulting revenue can be used in reducing the burden of the overall tax system and improving the performance of the economy, creating the double dividend of the title. The authors simulate the impact of environmental taxes on the U.S. economy using their Intertemporal General Equilibrium Model (IGEM). This highly innovative model incorporates expectations about future prices and policies. The model is estimated econometrically from an extensive 50-year dataset to incorporate the heterogeneity of producers and consumers. This approach generates confidence intervals for the outcomes of changes in economic policies, a new feature for models used in analyzing energy and environmental policies. These outcomes include the welfare impacts on individual households, distinguished by demographic characteristics, and for society as a whole, decomposed between efficiency and equity.
Book Synopsis Comparison of US, UK and German corporate income tax systems with respect to dividend relief by : Benjamin Mahr
Download or read book Comparison of US, UK and German corporate income tax systems with respect to dividend relief written by Benjamin Mahr and published by GRIN Verlag. This book was released on 2004-08-12 with total page 29 pages. Available in PDF, EPUB and Kindle. Book excerpt: Essay from the year 2004 in the subject Business economics - Accounting and Taxes, grade: Distinction (83%), The University of Sydney (Faculty of Law), course: Comparative Corporate Taxation, language: English, abstract: This essay briefly describes the main different theoretical approaches (tax systems) designed to alleviate the double burden of corporation tax and shareholder income tax under Part 2. Parts 3- 5 explain how the problem of dividend double taxation was tried to be solved in the heterogeneous tax systems of the Germany, the UK and the US. However, the essay will not cover the different double tax avoiding treaties in force in those countries.
