Corporate Taxes 2003 2004

Large international corporations and accountants representing international interests require the most up-to-date information regarding tax issues in countries around the world. Corporate Taxes 2003-2004 provides vital information on the corporate implications of the tax systems of over 120 countries.

Large international corporations and accountants representing international interests require the most up-to-date information regarding tax issues in countries around the world. Worldwide Summaries provides in two volumes vital information on the tax systems of over 120 countries. Volume 1 is for corporate tax and Volume 2 is for individual tax.

Clear, concise, and engaging, Fundamentals of Corporate Taxation teaches the fundamentals of a highly complex subject with skillfully drafted problems, explanatory text, and a selective mix of original source materials. The coursebook incorporates all relevant changes from recent acts, including the American Jobs Creation Act of 2004 and the Jobs and Growth Tax Relief Reconciliation Act of 2003. Important new highlights include discussions on the impact of reduced tax rates on qualified dividends, new rules limiting the transfer or importation of built-in-losses, and the response by courts and the Internal Revenue Service to corporate tax shelters. The sixth edition also contains new material on corporate reorganizations and S corporations, rulings on Section 351 control requirements and corporate divisions, and more permissive eligibility requirements and other new statutory rules.

This text is appropriate for one- or two-term courses covering personal and corporate taxation. Written in an accessible style, this text assumes that the student has no previous education in taxation. Byrd & Chen's Canadian Tax Principles can be used with or without other source materials (this includes the Income Tax Act, Information Circulars, Interpretation Bulletins, and other official materials). The Income Tax Act is referenced in the text where appropriate for further independent study. Students should be able to solve all of the end-of-chapter problems by relying solely on the text as a reference. The text and problem materials are comprehensive of the syllabus requirements of the CGAs, CAs, and CMAs.

The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.

This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).