Report Of The Department Of The Treasury On Integration Of The Individual And Corporate Tax Systems

Excerpt from Report of the Department of the Treasury on Integration of the Individual and Corporate Tax Systems: Taxing Business Income Once The so - called classical system of current u.s. Tax law treats corporations and their investors as separate entities and levies tax at both the corporate and shareholder levels on earnings from investments in corporate equity. Corporate earnings distributed to lenders as interest are generally deductible by the corporation and taxed, if at all, to the lender. Investors who conduct business activity in noncorporate form, such as a sole proprietorship or partnership, are taxed once on their earnings at the owners' tax rate. As a result, despite the critical role played by corporations as a vehicle for economic growth, the United States tax law often perversely penalizes the corporate form of organization. The current system of taxation also distorts corporate financial decisions - in particular by encouraging debt and discouraging new equity financing of corporate investments. The tax system also prejudices corporate decisions about whether to retain earnings or pay dividends and encourages corporations to distribute earnings in a manner to avoid the double level tax. Integration of the individual and corporate tax system would tax corporate income once and reduce or eliminate these economic distortions. Most trading partners of the United States have integrated their corporate tax systems. The potential economic gains from integration are substantial. This Report examines in detail several different integration prototypes, although it does not attempt an exhaustive discussion of all possible integration systems or of all the technical issues raised by the alternative prototypes. This Report does not contain legislative recommendations. Rather, it is intended to stimulate discussion of the various prototypes and issues they raise. By advancing the opportunity for such debate, this Report should encourage serious consideration of proposals for integrating the individual and corporate tax systems in the United States. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.

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The taxation of equity derivatives and structured products is analyzed in detail by Tony Rumble and his contributors, Mohammed Amin and Ed Kleinbard. The book covers the financial and tax technical analysis of issues relating to equity derivatives and structured products. Part 1 examines the derivatives building blocks and financial market/corporate finance drivers of the equity derivatives and financial products market, and includes case studies of typical and landmark transactions. Part 2 looks at the tax technical rules in each of the target countries - the US, UK and Australia - and examines the specific products highlighted in the first part of the book. Case studies of significant transactions are included where necessary.