Tax Planning Strategies (Continued) Four Key Strategies to Reduce Your Taxes (Legally): 1
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TAX REFORM and SMALL BUSINESS Eric J
REFERENCES TAX REFORM AND SMALL BUSINESS Eric J. Toder * Institute Fellow, Urban Institute and Co-Director, Urban-Brookings Tax Policy Center House Committee on Small Business April 15, 2015 Chairman Chabot, Ranking Member Velazquez, and Members of the Committee. Thank you for inviting me to appear today to discuss the effects of tax reform on small business. There is a growing consensus that the current system of taxing business income needs reform and bi-partisan agreement on some of the main directions of reform, although not the details. The main drivers for reform are concerns with a corporate tax system that discourages investment in the United States, encourages US multinational corporations to retain profits overseas, and places some US-based multinationals at a competitive disadvantage with foreign- based companies, while at the same time raising relatively little revenue, providing selected preferences to favored assets and industries, and allowing some US multinationals to pay very low tax rates by shifting reported profits to low tax countries. • The United States has the highest corporate tax rate in the Organization of Economic Cooperation and Development (OECD). This discourages investment in the United States by both US and foreign-based multinational corporations and encourages corporations to report income in other jurisdictions. • The US rules for taxing multinational corporations encourage US firms to earn and retain profits overseas and place some companies at a competitive disadvantage, encouraging *The views expressed are my own and should not be attributed to the Tax Policy Center or the Urban Institute, its board, or its funders. I thank Leonard Burman, Donald Marron, and George Plesko for helpful comments and Joseph Rosenberg, and John Wieselthier for assistance with the Tax Policy Center simulations. -
Owens: the Foreign Tax Credit
REVIEWS THE FoREIGN TAx CREDIT. By Elizabeth A. Owens. Cambridge: The Law School of Harvard University, 1961. Pp. xxxi, 634. $20.00. THE foreign tax credit provisions of the Internal Revenue Code embody United States policy toward the taxation of the foreign source income of do- mestic taxpayers. By allowing credit for foreign income taxes paid, or con- sidered paid, by domestic corporations, citizens and residents, the United States asserts only a secondary claim to the foreign source income of such taxpayers. In other words, foreign governments are regarded as having the primary right to tax income arising from sources within their borders up to the burden im- posed by the United States. The foreign tax credit device thereby serves the dual purpose of eliminating double taxation and of maintaining tax equality between domestic taxpayers with only domestic source income and those with foreign source income. The credit system, however, does not work perfectly in all instances; the statutory provisions contained in five sections of the Code ' have been subject to considerable controversy and many unanswered questions remain. These questions of law and policy are the main concern of The Foreign Tax Credit. The scope of the work may be considered from a number of viewpoints. In the first place, it may be considered from the standpoint of how fully the prob- lems of the foreign tax credit have been developed. Second, the scope of the treatment of important collateral areas may be appraised. Third, the book may be examined in terms of the depth of its analysis of common as well as the heretofore neglected problems. -
Taxation: State and Local Ronald H
Loyola University Chicago Law Journal Volume 18 Article 15 Issue 2 Winter 1986 1985-1986 Illinois Law Survey 1986 Taxation: State and Local Ronald H. Jacobson Follow this and additional works at: http://lawecommons.luc.edu/luclj Part of the Taxation-State and Local Commons Recommended Citation Ronald H. Jacobson, Taxation: State and Local, 18 Loy. U. Chi. L. J. 767 (1986). Available at: http://lawecommons.luc.edu/luclj/vol18/iss2/15 This Article is brought to you for free and open access by LAW eCommons. It has been accepted for inclusion in Loyola University Chicago Law Journal by an authorized administrator of LAW eCommons. For more information, please contact [email protected]. Taxation: State and Local Ronald H. Jacobson* TABLE OF CONTENTS I. INTRODUCTION .................................... 767 II. INCOME TAXATION ................................ 768 A. Unitary Taxation .............................. 768 B. Tax-Exempt Financing......................... 771 C. Interest on Federally GuaranteedBonds ........ 773 III. PROPERTY TAXATION .............................. 776 A. Charitableand EducationalExemptions ........ 776 B. Condominium Assessment Classifications ....... 778 IV. SALES TAXATION - USE TAX EXEMPTION ........ 780 V. TAX PROTESTING .................................. 782 A . Property Tax .................................. 782 B. Retaliatory Tax ................................ 784 VI. LOCAL GOVERNMENT TAXING POWERS ............ 786 A. County Tax Penalty Retention ................. 786 B. Taxation by Home Rule Units ................ -
Chapter 5 Foreign Tax Credit P.302 Structural Tax Options for an Outbound U.S
Chapter 5 Foreign Tax Credit p.302 Structural tax options for an outbound U.S. enterprise in (1) foreign destination country and (2) any conduit country: 1) Branch (e.g., a disregarded entity) - current U.S. income taxation on profits & loss deduction availability in the U.S. 2) Foreign corporate subsidiary - income tax deferral of U.S. income tax & no possible U.S. loss utilization Is the entity decision controlled by (1) tax planning or (2) non-tax business considerations? 4/9/2013 (c) William P. Streng 1 Mitigating Possible Double National Level Taxation Possible double taxation exposure exists (1) since the U.S. income tax is imposed on a worldwide basis & (2) assuming foreign country income tax. Options for unilateral relief (as provided by U.S.): 1) a tax deduction for the foreign tax paid (not completely eliminating double taxation) 2) a (limited) credit for the foreign tax paid (primarily used by U.S.); limited to offsetting U.S. tax on taxpayer’s foreign income. 3) exemption under a territorial system (only 4/9/2013source country taxation)(c) William P. Strengand not in U.S. 2 Bilateral (i.e., Income Tax Treaty) Relief p.306 Double tax relief accomplished under a U.S. bilateral income tax treaty. See U.S. Model, Article 23 (2006). - possible shifting of the primary income tax liability from source location to residence jurisdiction. - but, a U.S. income tax treaty does include a “savings clause” - enabling the continuing worldwide tax jurisdiction of U.S. citizens, residents or corporations. 4/9/2013 (c) William P. -
An Analysis of the Graded Property Tax Robert M
TaxingTaxing Simply Simply District of Columbia Tax Revision Commission TaxingTaxing FairlyFairly Full Report District of Columbia Tax Revision Commission 1755 Massachusetts Avenue, NW, Suite 550 Washington, DC 20036 Tel: (202) 518-7275 Fax: (202) 466-7967 www.dctrc.org The Authors Robert M. Schwab Professor, Department of Economics University of Maryland College Park, Md. Amy Rehder Harris Graduate Assistant, Department of Economics University of Maryland College Park, Md. Authors’ Acknowledgments We thank Kim Coleman for providing us with the assessment data discussed in the section “The Incidence of a Graded Property Tax in the District of Columbia.” We also thank Joan Youngman and Rick Rybeck for their help with this project. CHAPTER G An Analysis of the Graded Property Tax Robert M. Schwab and Amy Rehder Harris Introduction In most jurisdictions, land and improvements are taxed at the same rate. The District of Columbia is no exception to this general rule. Consider two homes in the District, each valued at $100,000. Home A is a modest home on a large lot; suppose the land and structures are each worth $50,000. Home B is a more sub- stantial home on a smaller lot; in this case, suppose the land is valued at $20,000 and the improvements at $80,000. Under current District law, both homes would be taxed at a rate of 0.96 percent on the total value and thus, as Figure 1 shows, the owners of both homes would face property taxes of $960.1 But property can be taxed in many ways. Under a graded, or split-rate, tax, land is taxed more heavily than structures. -
Canada Taxation of Foreign Passive Income (FAPI)
INTERNATIONAL TAX POLICY FORUM / GEORGETOWN UNIVERSITY LAW CENTER Reform of International Tax: Canada, Japan, United Kingdom, and United States January 21, 2011 Gewirz Student Center, 12th floor 120 F Street, N.W., Washington, D.C. 20036 International Tax Policy Forum International Tax Policy Forum and Georgetown University Law Center Conference on: REFORM OF INTERNATIONAL TAX: CANADA, JAPAN, UNITED KINGDOM, AND UNITED STATES Table of Contents 1) Agenda ................................................................................................................................................... 1 2) Sponsoring Organizations a) About ITPF ....................................................................................................................................... 2 b) About Georgetown University Law Center ....................................................................................... 3 3) Taxation of International Income in Canada, Japan, UK, and US a) International Tax Rules in Canada, Japan, the UK and US (J. Mintz Presentation) ....................... 4 b) Canada i) S. Richardson, Presentation on Canadian international tax reform (Jan. 2011) ....................... 9 ii) N. Pantaleo, Presentation on Canada's taxation of foreign business income (Jan. 2011) ..... 12 iii) Advisory Panel on Canada’s System of International Taxation, Enhancing Canada’s International Tax Advantage, (Dec. 2008) [Executive Summary] ........................................... 16 c) UK i) M. Williams, Presentation on UK international tax -
Imports in GST Regime (Goods & Services Tax)
Imports in GST Regime (Goods & Services Tax) Introduction Under the GST regime, Article 269A constitutionally mandates that supply of goods, or of services, or both in the course of import into the territory of India shall be deemed to be supply of goods, or of services, or both in the course of inter-State trade or commerce. So import of goods or services will be treated as deemed inter-State supplies and would be subject to Integrated tax. While IGST on import of services would be leviable under the IGST Act, the levy of the IGST on import of goods would be levied under the Customs Act, 1962 read with the Custom Tariff Act, 1975. The importer of services will have to pay tax on reverse charge basis. However, in respect of import of online information and database access or retrieval services (OIDAR) by unregistered, non-taxable recipients, the supplier located outside India shall be responsible for payment of taxes (IGST). Either the supplier will have to take registration or will have to appoint a person in India for payment of taxes. Supply of goods or services or both to a Special Economic Zone developer or a unit shall be treated as inter-State supply and shall be subject to levy of integrated tax. Directorate General of Taxpayer Services CENTRAL BOARD OF EXCISE & CUSTOMS www.cbec.gov.in Imports in GST Regime (Goods & Services Tax) Importer Exporter Code (IEC): As per DGFT’s Trade Notice No. 09 The taxes will be calculated as under: dated 12.06.2017, the PAN of an entity would be used as the Import Particulars Duty Export code (IEC). -
Should EU Implement Its Present Proposal of a Financial Transaction Tax?
Should EU implement its present proposal of a financial transaction tax? Authors: Fredrik Hansson (890429-4033) Tutor: Thomas Ericson Degree of Bachelor of Science in Examiner: Dominique Anxo Business Administration and Subject: Economics Economics Level and semester: Bachelor´s Thesis, Spr 2012 Abstract: This paper study the possibility of implementing a financial transaction tax within the European Union, as a possibility to discourage future financial bubbles and force more fundamental values within the financial market. It is found, after reviewing current research; covering volatility, market volume and speculation, and empirical evidence, that a financial transaction tax fulfill the purpose of creating a more efficient financial system in the case of European Union. Table of Contents Introduction .......................................................................................................................................... 3 Theoretical framework .......................................................................................................................... 3 Empirical studies ................................................................................................................................ 10 United Kingdom ............................................................................................................................. 10 Sweden ........................................................................................................................................... 11 Hong Kong, Japan, -
European Parliament Resolution of 26 March 2019 on Financial Crimes, Tax Evasion and Tax Avoidance (2018/2121(INI)) (2021/C 108/02)
C 108/8 EN Official Journal of the European Union 26.3.2021 Tuesday 26 March 2019 P8_TA(2019)0240 Report on financial crimes, tax evasion and tax avoidance European Parliament resolution of 26 March 2019 on financial crimes, tax evasion and tax avoidance (2018/2121(INI)) (2021/C 108/02) The European Parliament, — having regard to Articles 4 and 13 of the Treaty on European Union (TEU), — having regard to Articles 107, 108, 113, 115 and 116 of the Treaty on the Functioning of the European Union (TFEU), — having regard to its decision of 1 March 2018 on setting up a special committee on financial crimes, tax evasion and tax avoidance (TAX3), and defining its responsibilities, numerical strength and term of office (1), — having regard to its TAXE committee resolution of 25 November 2015 (2) and its TAX2 committee resolution of 6 July 2016 (3) on tax rulings and other measures similar in nature or effect, — having regard to its resolution of 16 December 2015 with recommendations to the Commission on bringing transparency, coordination and convergence to corporate tax policies in the Union (4), — having regard to the results of the Committee of Inquiry into money laundering, tax avoidance and tax evasion, which were submitted to the Council and the Commission on 13 December 2017 (5), — having regard to the Commission’s follow-up to each of the above-mentioned Parliament resolutions (6), — having regard to the numerous revelations by investigative journalists, such as the LuxLeaks, the Panama Papers, the Paradise Papers and, more recently, the cum-ex scandals, as well as the money laundering cases involving, in particular, banks in Denmark, Estonia, Germany, Latvia, the Netherlands and the United Kingdom, — having regard to its resolution of 29 November 2018 on the cum-ex scandal: financial crime and loopholes in the current legal framework (7), (1) Decision of 1 March 2018 on setting up a special committee on financial crimes, tax evasion and tax avoidance (TAX3), and defining its responsibilities, numerical strength and term of office, Texts adopted, P8_TA(2018)0048. -
ITEMIZING on STATE and FEDERAL TAX INCOME RETURNS: IT’S (NOW MORE) COMPLICATED David Weiner December 2, 2020
ITEMIZING ON STATE AND FEDERAL TAX INCOME RETURNS: IT’S (NOW MORE) COMPLICATED David Weiner December 2, 2020 A taxpayer’s decision to itemize deductions or to claim the standard deduction on their income tax return is often framed as a simple calculation: Claim the greater of the two so as to minimize tax liability. But in states that require taxpayers to use the same status on their state income tax return as on their federal return, this general rule can produce conflicting results if taxpayers examine liability separately on their federal and state returns. Itemized deductions might be greater than the standard deduction on a state income tax return, but the reverse could be true on a federal return. Recent federal law changes have further complicated the choice. When the federal standard deduction was nearly doubled beginning in 2018, many more taxpayers found a conflict between the best itemization scenario on federal and state income tax returns. Those taxpayers must now calculate their federal and state income taxes under both scenarios if they want to minimize their combined state and federal income tax liability. Many taxpayers in states that link federal and state itemization choices are affected. In Maryland, for example, more than 200,000 taxpayers could benefit by itemizing on their federal returns when that may not be the obvious choice. In this brief, I examine the links between federal and state itemization decisions and explore the implications of relaxing state rules requiring that state itemization choices match federal ones. elatively few federal taxpayers itemize deductions on their income tax returns under current law, and those who do tend to have very high incomes. -
FINANCE Offshore Finance.Pdf
This page intentionally left blank OFFSHORE FINANCE It is estimated that up to 60 per cent of the world’s money may be located oVshore, where half of all financial transactions are said to take place. Meanwhile, there is a perception that secrecy about oVshore is encouraged to obfuscate tax evasion and money laundering. Depending upon the criteria used to identify them, there are between forty and eighty oVshore finance centres spread around the world. The tax rules that apply in these jurisdictions are determined by the jurisdictions themselves and often are more benign than comparative rules that apply in the larger financial centres globally. This gives rise to potential for the development of tax mitigation strategies. McCann provides a detailed analysis of the global oVshore environment, outlining the extent of the information available and how that information might be used in assessing the quality of individual jurisdictions, as well as examining whether some of the perceptions about ‘OVshore’ are valid. He analyses the ongoing work of what have become known as the ‘standard setters’ – including the Financial Stability Forum, the Financial Action Task Force, the International Monetary Fund, the World Bank and the Organization for Economic Co-operation and Development. The book also oVers some suggestions as to what the future might hold for oVshore finance. HILTON Mc CANN was the Acting Chief Executive of the Financial Services Commission, Mauritius. He has held senior positions in the respective regulatory authorities in the Isle of Man, Malta and Mauritius. Having trained as a banker, he began his regulatory career supervising banks in the Isle of Man. -
Illinois Department of Revenue Regulations Title 86 Part 100 Section 2197 FOREIGN TAX CREDIT
Illinois Department of Revenue Regulations Title 86 Part 100 Section 2197 FOREIGN TAX CREDIT (IITA SECTION 601 (b)(3)) TITLE 86: REVENUE CHAPTER I: DEPARTMENT OF REVENUE PART 100 Income Tax Section 100.2197 Foreign Tax Credit (IITA Section 601(b)(3)) a) IITA Section 601(b)(3) provides that the aggregate amount of tax which is imposed upon or measured by income and which is paid by a resident for a taxable year to another state or states on income which is also subject to the tax imposed by IITA Section 201(a) and (b) shall be credited against the tax imposed by IITA Section 201(a) and (b) otherwise due under the IITA for that taxable year. (IITA Section 601(b)(3)) b) Definitions applicable to this Section. 1) Tax qualifying for the credit. A tax qualifies for the credit only if it is imposed upon or measured by income and is paid by an Illinois resident to another state on income which is also subject to Illinois income tax. A) A tax "imposed upon or measured by income" shall mean an income tax or tax on profits imposed by a state and deductible under IRC section 164(a)(3). The term shall not include penalties or interest imposed with respect to the tax. B) A tax is "paid by an Illinois resident" to another state "on income which is also subject to Illinois income tax" only to the extent the income included in the tax base of the other state is also included in base income computed under IITA Section 203 during a period in which the taxpayer is an Illinois resident.