Understanding Corporate Taxation

Understanding Corporate Taxation PDF

Author: Leandra Lederman

Publisher:

Published: 2016

Total Pages: 0

ISBN-13: 9781632833945

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This clearly written treatise is designed to make very accessible the complex subject of corporate taxation by using non-technical, straightforward language, charts, checklists, diagrams, and numerous examples to aid readers' understanding. The book starts with an introductory chapter that discusses the choice of business form; the general principle that corporate profits are subject to double taxation (once at the corporate level and again at the shareholder level); and the basics of anti-abuse rules, such as the step-transaction doctrine. Those anti-abuse rules are explored in more detail in a later chapter, as are proposals to partially or fully eliminate double taxation. The next several chapters are organized using a cradle-to-grave approach that traces the life cycle of a corporation, beginning with formation and capitalization and ending with corporate "death," liquidation. Between those events, the book discusses operational issues, including the capital structure of a corporation, distributions of cash or property, stock redemptions, and stock dividends. After corporate liquidations, the book explores more advanced topics, such as taxable stock or asset acquisitions; non-taxable corporate reorganizations and divisions; the carryover of tax attributes (such as net operating losses) following certain non-recognition transactions; and the treatment of corporate tax shelters. In addition, a chapter addresses the taxation of S corporations, which generally provides a single-tax paradigm. Understanding Corporate Taxation also includes discussion of relevant cases. It is designed to supplement any corporate tax casebook or to be used on its own.

Confidence Games

Confidence Games PDF

Author: Tanina Rostain

Publisher: MIT Press

Published: 2014-04-25

Total Pages: 421

ISBN-13: 0262027135

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The rise and fall of a tax shelter industry that enabled some of America's richest citizens to avoid paying their fair share of taxes. For ten boom-powered years at the turn of the twenty-first century, some of America's most prominent law and accounting firms created and marketed products that enabled the very rich—including newly minted dot-com millionaires—to avoid paying their fair share of taxes by claiming benefits not recognized by law. These abusive domestic tax shelters bore such exotic names as BOSS, BLIPS, and COBRA and were developed by such prestigious firms as KPMG and Ernst & Young. They brought in hundreds of millions of dollars in fees from clients and bilked the U.S. Treasury of billions in revenues before the IRS and Justice Department stepped in with civil penalties and criminal prosecutions. In Confidence Games, Tanina Rostain and Milton Regan describe the rise and fall of the tax shelter industry during this period, offering a riveting account of the most serious episode of professional misconduct in the history of the American bar. Rostain and Regan describe a beleaguered IRS preoccupied by attacks from antitax and antigovernment politicians; heightened competition for professional services; the relaxation of tax practitioner norms against aggressive advice; and the creation of complex financial instruments that made abusive shelters harder to detect. By 2004, the tax shelter boom was over, leaving failed firms, disgraced professionals, and prison sentences in its wake. Rostain and Regan's cautionary tale remains highly relevant today, as lawyers and accountants continue to face intense competitive pressure and regulators still struggle to keep pace with accelerating financial risk and innovation.

The Hidden Wealth of Nations

The Hidden Wealth of Nations PDF

Author: Gabriel Zucman

Publisher: University of Chicago Press

Published: 2015-09-22

Total Pages: 142

ISBN-13: 022624556X

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We are well aware of the rise of the 1% as the rapid growth of economic inequality has put the majority of the world’s wealth in the pockets of fewer and fewer. One much-discussed solution to this imbalance is to significantly increase the rate at which we tax the wealthy. But with an enormous amount of the world’s wealth hidden in tax havens—in countries like Switzerland, Luxembourg, and the Cayman Islands—this wealth cannot be fully accounted for and taxed fairly. No one, from economists to bankers to politicians, has been able to quantify exactly how much of the world’s assets are currently hidden—until now. Gabriel Zucman is the first economist to offer reliable insight into the actual extent of the world’s money held in tax havens. And it’s staggering. In The Hidden Wealth of Nations, Zucman offers an inventive and sophisticated approach to quantifying how big the problem is, how tax havens work and are organized, and how we can begin to approach a solution. His research reveals that tax havens are a quickly growing danger to the world economy. In the past five years, the amount of wealth in tax havens has increased over 25%—there has never been as much money held offshore as there is today. This hidden wealth accounts for at least $7.6 trillion, equivalent to 8% of the global financial assets of households. Fighting the notion that any attempts to vanquish tax havens are futile, since some countries will always offer more advantageous tax rates than others, as well the counter-argument that since the financial crisis tax havens have disappeared, Zucman shows how both sides are actually very wrong. In The Hidden Wealth of Nations he offers an ambitious agenda for reform, focused on ways in which countries can change the incentives of tax havens. Only by first understanding the enormity of the secret wealth can we begin to estimate the kind of actions that would force tax havens to give up their practices. Zucman’s work has quickly become the gold standard for quantifying the amount of the world’s assets held in havens. In this concise book, he lays out in approachable language how the international banking system works and the dangerous extent to which the large-scale evasion of taxes is undermining the global market as a whole. If we are to find a way to solve the problem of increasing inequality, The Hidden Wealth of Nations is essential reading.

The Problem of Corporate Tax Shelters

The Problem of Corporate Tax Shelters PDF

Author: Department Of The Treasury

Publisher:

Published: 2013-06-25

Total Pages: 0

ISBN-13: 9781304171108

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The proliferation of corporate tax shelters presents an unacceptable and growing level of tax avoidance behavior. Over the past several years, Congress and the Administration repeatedly have provided targeted responses to specific shelters as they have come to light. The Administration believes that a generic solution to curb the growth of corporate tax shelters must be fashioned, as opposed to the current after-the-fact, ad hoc approach. This, admittedly, is not an easy task. Unlike the individual tax shelters of the 1970s and 1980s, corporate tax shelters may take several forms and do not rely on any single Code section or regulation. For this reason, they are hard to define. Nonetheless, the Administration in its Fiscal Year 2000 Budget proposed several generic remedies, focused on certain identified common characteristics, to curb the growth of corporate tax shelters. As Deputy Secretary Lawrence Summers recently stated, the Administration's proposals are intended ...