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EBOOK
Author Ting, Antony, 1962-
Title The taxation of corporate groups under consolidation : an international comparison / Antony Ting.
Imprint Cambridge : Cambridge University Press, 2012.

Author Ting, Antony, 1962-
Series Cambridge tax law series
Cambridge tax law series. http://id.loc.gov/authorities/names/no2006134461
Subject Corporations -- Taxation -- Law and legislation.
Income tax -- Law and legislation.
Fiscal policy.
Description 1 online resource (340 pages).
Contents Cover; The Taxation of Corporate Groups Under Consolidation; Series; Title; Copyright; Contents; Figures; Tables; Preface; Glossary of terms; Abbreviations; PART I The enterprise doctrine: theory and practice; 1 The rise of corporate groups: a challengeto the tax law; 1.1 The rise of corporate groups; 1.2 Tension between traditional legal principle and commercial reality; 1.3 Tax consolidation: a response to the rise of corporate groups; 1.4 The purpose, analytical approach and content of this book; 2 Application of the enterprise doctrine to group taxation:; 2.1 The separate entity doctrine.
2.1.1 Historical development of legal personality of companies2.1.2 Companies as separate taxable units; 2.1.3 The rise of corporate groups: a challenge to the doctrine; 2.2 The enterprise doctrine; 2.2.1 Development of the enterprise doctrine in corporation law; 2.2.2 The enterprise doctrine and the tax law; 2.2.3 Why is the enterprise doctrine more appropriate for the taxation of corporate groups?; 2.2.3.1 Criteria to judge a tax regime; 2.2.3.1 Criteria to judge a tax regime; 2.2.3.2 Justifications to apply the enterprise doctrine to group taxation regimes; (1) Simplicity; (1) Simplicity.
2.2.3.2 Justifications to apply the enterprise doctrine to group taxation regimes(1) Simplicity; (1) Simplicity; (2) Fairness; (2) Fairness; (2) Fairness; (2) Fairness; (3) Neutrality; (3) Neutrality; (3) Neutrality; (3) Neutrality; (4) Competitiveness; (4) Competitiveness; (4) Competitiveness; (4) Competitiveness; 2.3 Key dimensions of application of the enterprise doctrine; 2.3.1 Taxable unit; 2.3.2 Tax base; (1) Relationship to international tax norms; (1) Relationship to international tax norms; (2) Possible definition of tax base under the enterprise doctrine.
(I) A country group as the taxable unit(i) A country group as the taxable unit; (2) Possible definition of tax base under the enterprise doctrine; (i) A country group as the taxable unit; (i) A country group as the taxable unit; (ii) A bloc group or worldwide group as the taxable unit; (ii) A bloc group or worldwide group as the taxable unit; (ii) A bloc group or worldwide group as the taxable unit; (ii) A bloc group or worldwide group as the taxable unit; 2.4 Taxonomy of group taxation models under the enterprise doctrine; 3 Application of the enterprise doctrine to group taxation.
3.1 Key dimensions of application of the enterprise doctrine in practice(1) Taxable unit; (2) Tax base; 3.2 Application of the enterprise doctrine: corporate groups as taxable unit; (1) Group pooling; (2) Consolidation; (3) Consolidation of a bloc group -- CCCTB; (4) Worldwide group pooling; 3.3 Application of the enterprise doctrine: tax base of a company; (1) Tax free intra-group asset transfer22; (2) Group contribution; (3) Group loss relief; (4) Organschaft26; (5) Water's edge FA; (1) Combination of models; (2) Residence concept33; (3) Ideas vs reality.
Note 3.4 Application of the enterprise doctrine: key functions of a group taxation regime.
Summary Antony Ting presents the first comprehensive comparative study of the tax consolidation regimes adopted in eight countries.
Bibliography Note Includes bibliographical references and index.
Note Print version record.
ISBN 9781139616843
1139616846
9781283870702 (MyiLibrary)
1283870703 (MyiLibrary)
9781139626149 (electronic bk.)
1139626140 (electronic bk.)
9781139519786 (electronic bk.)
1139519786 (electronic bk.)
9781107033498
1107033497
OCLC # 823724185
Additional Format Print version: Ting, Antony. Taxation of Corporate Groups under Consolidation : An International Comparison. Cambridge : Cambridge University Press, ©2012 9781107033498


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