INTRODUCTION DFK INTERNATIONAL Is an Organisation Whose Membership Consists of Independent Accounting Firms and Business Advisers Throughout the World
Total Page:16
File Type:pdf, Size:1020Kb

Load more
Recommended publications
-
REPLACING CORPORATE TAX REVENUES with a MARK to MARKET TAX on SHAREHOLDER INCOME Eric Toder and Alan D
REPLACING CORPORATE TAX REVENUES WITH A MARK TO MARKET TAX ON SHAREHOLDER INCOME Eric Toder and Alan D. Viard October 2016 ABSTRACT We propose reducing the corporate tax rate to 15 percent and replacing the foregone revenue with a tax at ordinary income rates on the accrued, or mark-to-market income of American shareholders of publicly traded corporations, accompanied by an imputation credit for U.S. corporate income taxes paid. The proposal would dramatically reduce the tax significance of the source of corporate profits and the residence of corporations, both of which can be easily manipulated. Lowering the corporate tax rate to 15 percent would encouraging a capital inflow to the United States and reduce incentives to shift reported profits overseas and engage in inversion transactions while continuing to impose tax on foreigners who earn economic rents from investing in the United States. The proposal includes provisions for averaging of mark-to- market income, transition relief for firms that move from closely held to publicly traded status, and other measures to address the challenges of mark-to-market taxation. We estimate that the proposal would be approximately revenue-neutral and would make the distribution of the tax burden slightly more progressive. A revised version of the article was been published in the September 2016 issue of the National Tax Journal, Volume 69 (3), 701-731. The findings and conclusions contained within are those of the author and do not necessarily reflect positions or policies of the Tax Policy Center or its funders. I. INTRODUCTION This paper presents a proposal for reform of the taxation of corporate income. -
Double Taxation of Corporate Income in the United States and the OECD
Double Taxation of Corporate Income in the United States and the OECD FISCAL Taylor LaJoie Elke Asen FACT Policy Analyst Policy Analyst No. 740 Jan. 2021 Key Findings • The Tax Cuts and Jobs Act lowered the top integrated tax rate on corporate income distributed as dividends from 56.33 percent in 2017 to 47.47 percent in 2020; the OECD average is 41.6 percent. • Joe Biden’s proposal to increase the corporate income tax rate and to tax long-term capital gains and qualified dividends at ordinary income rates would increase the top integrated tax rate on distributed dividends to 62.73 percent, highest in the OECD. • Income earned in the U.S. through a pass-through business is taxed at an average top combined statutory rate of 45.9 percent. • On average, OECD countries tax corporate income distributed as dividends at 41.6 percent and capital gains derived from corporate income1 at 37.9 percent. • Double taxation of corporate income can lead to such economic distortions as reduced savings and investment, a bias towards certain business forms, and debt financing over equity financing. • Several OECD countries have integrated corporate and individual tax codes to eliminate or reduce the negative effects of double taxation on corporate The Tax Foundation is the nation’s income. leading independent tax policy research organization. Since 1937, our research, analysis, and experts have informed smarter tax policy at the federal, state, and global levels. We are a 501(c)(3) nonprofit organization. ©2021 Tax Foundation Distributed under Creative Commons CC-BY-NC 4.0 Editor, Rachel Shuster Designer, Dan Carvajal Tax Foundation 1325 G Street, NW, Suite 950 Washington, DC 20005 202.464.6200 1 In some countries, the capital gains tax rate varies by type of asset sold. -
Tax Policy Update 16 27 April
Policy update Tax Policy Update 16 27 April HIGHLIGHTS • European Parliament: Plenary discusses state of public CBCR negotiations 18 April • Council: member states freeze CCTB negotiations in order to assess its impact on tax bases 20 April • European Commission: new rules for whistleblower protection proposed, covers tax avoidance too 23 April • European Parliament: ECON Committee holds public hearing on definitive VAT system 24 April • European Commission: new Company Law Package with tax dimension published 25 April European Commission Commission kicks off Fair Taxation Roadshow 19 April The European Commission has launched a series of seminars on fair taxation, with a first event held in Riga on 19 April. These seminars bring together civil society, business representatives, policy makers, academics and interested citizens to discuss and exchange views on tax avoidance and tax evasion. Further events are planned throughout 2018 in Austria (17 May), France (8 June), Italy (19 September) and Ireland (9 October). The Commission hopes that the roadshow seminars will further encourage active engagement on tax fairness principles at EU, national and local levels. In particular, a main aim seems to be to spread the tax debate currently ongoing at the EU-level into member states as well. Commission launches VAT MOSS portal 19 April The European Commission has launched a Mini-One Stop Shop (MOSS) portal for VAT purposes. The new MOSS portal provides comprehensive and easily accessible information on VAT rates for telecom, broadcasting and e- services, and explains how the MOSS can be used to declare and pay VAT on such services. 1 Commission proposes EU rules for whistleblower protection, covers tax avoidance as well 23 April The European Commission has published a new Directive for the protection of whistleblowers. -
Tax Avoidance Due to the Zero Capital Gains Tax
2 Capital gains tax regimes abroad—countries without capital gains taxes Tax avoidance due to the zero capital gains tax Some indirect evidence from Hong Kong BERRY F. C . H SU AND CHI-WA YUEN Consistent with its image as a free-market economy with minimal government intervention, Hong Kong is a city with low and simple taxation. Unlike most industrial and developed economies with full-fledged tax structures, Hong Kong has a relatively narrow tax base. It has direct taxes, which account for about 60% of the total tax revenue. These direct levies fall on earnings and profits and in- clude an estate duty. Hong Kong also has indirect taxes, which ac- count for the remaining 40%. These consist of rates, duties, and taxes on motor vehicles and so on.1 Nonetheless, Hong Kong has neither a sales or value-added tax nor a capital gains tax. In this paper, we explain the absence of the capital gains tax and provide some indirect evidence on the tax-avoidance effects induced by this fact. Notes will be found on pages 51–53. 39 40 International evidence on capital gains taxes Why is there no capital gains tax in Hong Kong? Under the British colonial rule, no tax was levied on capital gains in Hong Kong.2 This continues to be the case since the Chinese gov- ernment took over in 1997. During the pre-1997 (colonial) period, the tax structure in Hong Kong was based on the British tax system, which uses the source concept of income for the taxation of different kinds of in- come. -
Financial Transaction Taxes
FINANCIAL MM TRANSACTION TAXES: A tax on investors, taxpayers, and consumers Center for Capital Markets Competitiveness 1 FINANCIAL TRANSACTION TAXES: A tax on investors, taxpayers, and consumers James J. Angel, Ph.D., CFA Associate Professor of Finance Georgetown University [email protected] McDonough School of Business Hariri Building Washington, DC 20057 202-687-3765 Twitter: @GUFinProf The author gratefully acknowledges financial support for this project from the U.S. Chamber of Commerce. All opinions are those of the author and do not necessarily reflect those of the Chamber or Georgetown University. 2 Financial Transaction Taxes: A tax on investors, taxpayers, and consumers FINANCIAL TRANSACTIN TAES: Table of Contents A tax on investors, taxpayers, and Executive Summary .........................................................................................4 consumers Introduction .....................................................................................................6 The direct tax burden .......................................................................................7 The indirect tax burden ....................................................................................8 The derivatives market and risk management .............................................. 14 Economic impact of an FTT ............................................................................17 The U.S. experience ..................................................................................... 23 International experience -
Guide to Fiscal Information
Guide to Fiscal Information Key Economies in Africa 2014/15 Preface This booklet contains a summary of tax and investment information pertaining to key countries in Africa. This year’s edition of the booklet has been expanded to include an additional five countries over- and-above the thirty-five countries featured in last year’s edition. The forty countries featured this year comprise: Algeria, Angola, Benin, Botswana, Burkina Faso, Burundi, Cameroon, Chad, Congo (Brazzaville), Democratic Republic of Congo (DRC), Egypt, Ethiopia, Equatorial Guinea, Gabon, The Gambia, Ghana, Guinea Conakry, Ivory Coast, Kenya, Lesotho, Libya, Madagascar, Malawi, Mauritania, Mauritius, Morocco, Mozambique, Namibia, Nigeria, Rwanda, Senegal, Sierra Leone, South Africa, South Sudan, Swaziland, Tanzania, Tunisia, Uganda, Zambia and Zimbabwe. Details of each country’s income tax, VAT (or sales tax), and other significant taxes are set out in the publication. In addition, investment incentives available, exchange control regimes applicable (if any) and certain other basic economic statistics are detailed. The contact details for each country are provided on the cover page of each country chapter/ section and also summarised on page 4, Tax Leaders in Africa. An introduction to the Africa Tax Desk (including relevant contact details) is provided on page 3, Africa Tax Desk. This booklet has been prepared by the Tax Division of Deloitte. Its production was made possible by the efforts of: • Moray Wilson, Adrienne Snyman and Susan Heiman – editorial management, content and design. • Bruno Messerschmitt, Musa Manyathi and Sarah Naiyeju – Deloitte Africa Tax Desk. • Deloitte colleagues (and Independent Correspondent Firm staff where necessary) in various cities/offices in Africa and elsewhere. -
Dividends and Capital Gains Information Page 1 of 2
Dividends and Capital Gains Information Page 1 of 2 Some of the dividends you receive and all net long term capital gains you recognize may qualify for a federal income tax rate As noted above, for purposes of determining qualified dividend lower than your federal ordinary marginal rate. income, the concept of ex-dividend date is crucial. The ex- dividend date of a fund is the first date on which a person Qualified Dividends buying a fund share will not receive any dividends previously declared by the fund. A list of fund ex-dividend dates for each Qualified dividends received by you may qualify for a 20%, 15% State Farm Mutual Funds® dividend paid with respect to 2020, or 0% tax rate depending on your adjusted gross income (or and the corresponding percentage of each dividend that may AGI) and filing status. For single filing status, the qualified qualify as qualified dividend income, is provided below for your dividend tax rate is 0% if AGI is $40,000 or less, 15% if AGI is reference. more than $40,000 and equal to or less than $441,450, and 20% if AGI is more than $441,450. For married filing jointly Example: status, the qualified dividend tax rate is 0% if AGI is $80,000 or You bought 10,000 shares of ABC Mutual Fund common stock less, 15% if AGI is more than $80,000 and equal to or less than on June 8, 2020. ABC Mutual Fund paid a dividend of 10 cents $496,600, and 20% if AGI is more than $496,600. -
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. -
The High Burden of State and Federal Capital Gains Tax Rates in the United FISCAL FACT States Mar
The High Burden of State and Federal Capital Gains Tax Rates in the United FISCAL FACT States Mar. 2015 No. 460 By Kyle Pomerleau Economist Key Findings · The average combined federal, state, and local top marginal tax rate on long-term capital gains in the United States is 28.6 percent – 6th highest in the OECD. · This is more than 10 percentage points higher than the simple average across industrialized nations of 18.4 percent, and 5 percentage points higher than the weighted average. · Nine industrialized countries exempt long-term capital gains from taxation. · California has the 3rd highest top marginal capital gains tax rate in the industrialized world at 33 percent. · The taxation of capital gains places a double-tax on corporate income, increases the cost of capital, and reduces investment in the economy. · The President’s FY 2016 budget would increase capital gains tax rates in the United States from 28.6 percent to 32.8, the 5th highest rate in the OECD. 2 Introduction Saving is important to an economy. It leads to higher levels of investment, a larger capital stock, increased worker productivity and wages, and faster economic growth. However, the United States places a heavy tax burden on saving and investment. One way it does this is through a high top marginal tax rate on capital gains. Currently, the United States’ top marginal tax rate on long-term capital gains income is 23.8 percent. In addition, taxpayers face state and local capital gains tax rates between zero and 13.3 percent. As a result, the average combined top marginal tax rate in the United States is 28.6 percent. -
Country Update: Australia
www.pwc.com Country update: Australia Anthony Klein Partner, PwC Australia Liam Collins Partner, PwC Singapore Agenda 1. Economic and social challenges 2. Tax and politics 3. Recent developments 4. 2015 Federal Budget – key announcements 5. Regulatory environment – changes at the ATO 6. Q&A Global Tax Symposium – Asia 2015 PwC 2 Economic and social challenges Global Tax Symposium – Asia 2015 PwC 3 $ billion 10,000 12,000 14,000 ‐ 2,000 4,000 6,000 8,000 2,000 PwC Tax – Symposium Global 2015 Asia Economic outlook 0 Australia’s net debt levels, A$ billion net debt levels, Australia’s 2002‐03 2003‐04 2004‐05 2005‐06 2006‐07 2007‐08 2008‐09 2009‐10 2010‐11 2011‐12 2012‐13 2013‐14 2014‐15 2015‐16 Commonwealth 2016‐17 2017‐18 2018‐19 2019‐20 Current year 2020‐21 2021‐22 2022‐23 States 2023‐24 2024‐25 and 2025‐26 territories 2026‐27 2027‐28 2028‐29 2029‐30 2030‐31 Federation 2031‐32 2032‐33 2033‐34 2034‐35 2035‐36 2036‐37 2037‐38 2038‐39 2039‐40 2040‐41 2041‐42 2042‐43 2043‐44 2044‐45 2045‐46 2046‐47 2047‐48 2048‐49 2049‐50 4 Impact of iron ore prices and AUD 1980 to 2015 200.00 1.5000 180.00 1.3000 160.00 140.00 1.1000 120.00 0.9000 Iron Ore Price 100.00 AUD:USD 0.7000 80.00 60.00 0.5000 40.00 0.3000 20.00 0.00 0.1000 Global Tax Symposium – Asia 2015 PwC 5 Domestic challenges Domestic economy • Declining per capita income • Government spending previously underpinned by resources boom – now less affordable • As a consequence, deficits ‘as far as the eye can see’ • A Government short on political capital Demographic challenges • Ageing population -
Taxation of Cross-Border Mergers and Acquisitions
KPMG INTERNATIONAL Taxation of Cross-Border Mergers and Acquisitions Jersey kpmg.com 2 | Jersey: Taxation of Cross-Border Mergers and Acquisitions Jersey Introduction Recent developments Jersey is a dependency of the British Crown and benefits The EU Code of Conduct on Business Taxation Group from close ties to both the United Kingdom, being in the assessed Jersey’s zero/ten tax system in 2011. The same time zone and having a similar regulatory environment assessment found that the interaction of the zero percent and business culture, and Europe. With its long tradition of rate and the deemed dividend and full attribution provisions to political and economic stability, low-tax regime and economy be harmful. The dividend and attribution provisions sought to dominated by financial institutions, Jersey is an attractive assess Jersey resident individual shareholders on the profits location for investment. of Jersey companies subject to the zero percent rate. As a result of the assessment, legislation was passed to abolish The island has undertaken steps to counter its tax haven the deemed distribution and full attribution taxation provisions image in recent times. It was placed on the Organisation for for profits arising on or after 1 January 2012, thereby removing Economic Cooperation and Development (OECD) white list the harmful element of the regime. The EU Code of Conduct in April 2009. In September 2009, the International Monetary on Business Taxation Group accepted Jersey’s position Fund issued a report in which it commented that financial and submitted to the EU’s Economic and Financial Affairs sector regulation and supervision are of a high standard and Council (ECOFIN) that Jersey had rolled back the harmful comply well with international standards. -
What's Wrong with a Federal Inheritance Tax? Wendy G
University of Baltimore Law ScholarWorks@University of Baltimore School of Law All Faculty Scholarship Faculty Scholarship Spring 2014 What's Wrong with a Federal Inheritance Tax? Wendy G. Gerzog University of Baltimore School of Law, [email protected] Follow this and additional works at: http://scholarworks.law.ubalt.edu/all_fac Part of the Estates and Trusts Commons, Taxation-Federal Commons, Taxation-Federal Estate and Gift ommonC s, and the Tax Law Commons Recommended Citation What's Wrong with a Federal Inheritance Tax?, 49 Real Prop. Tr. & Est. L.J. 163 (2014-2015) This Article is brought to you for free and open access by the Faculty Scholarship at ScholarWorks@University of Baltimore School of Law. It has been accepted for inclusion in All Faculty Scholarship by an authorized administrator of ScholarWorks@University of Baltimore School of Law. For more information, please contact [email protected]. WHAT'S WRONG WITH A FEDERAL INHERITANCE TAX? Wendy C. Gerzog* Synopsis: Scholars have proposed a federal inheritance tax as an alternative to the current federal transfer taxes, but that proposal is seriously flawed. In any inheritance tax model, scholars should expect to see significantly decreased compliance rates and increased administrative costs because, by focusing on the transferees instead of on the transferor, an inheritance tax would multiply the number oftaxpayers subject to the tax. This Article reviews common characteristics ofexisting inheritance tax systems in the United States and internationally-particularly in Europe. In addition, the Article analyzes the novel Comprehensive Inheritance Tax (CIT) proposal, which combines some elements of existing inheritance tax systems with some features ofthe current transfer tax system and delivers the CIT through the federal income tax system.