Die Verschmelzung als wirtschaftlich und rechtlich engste Form der Unternehmensverbindung stellt in einer dynamischen Wirtschaft ein nie an Aktualität einbüßendes Thema dar. Umfassend und fachübergreifend werden neben betriebswirtschaftlichen auch handels- und gesellschaftsrechtliche Aspekte sowie steuerliche Fragestellungen betrachtet. Dabei bildet die Darstellung des Verschmelzungsvorgangs in Handelsbilanzen von Überträgerin und Übernehmerin den Schwerpunkt der Analyse. Das Bewertungswahlrecht zwischen Buchwertverknüpfung und Anschaffungskostenansatz der Übernehmerin in § 24 UmwG wird ausführlich für verschiedene Gegenleistungen untersucht. Durch zahlreiche Beispiele, Tabellen und Abbildungen ist das Buch für Wissenschaft und Praxis gleichermaßen geeignet.

This book clearly chronicles the evolution of Chinese VAT regulations, with a particular focus on the reforms of recent years. Covering all the provisions of the laws related to VAT, it also provides examples and implementation instructions. Practically structured and easy to consult, it allows readers to quickly find answers to questions that may arise in the course of their work. As such, the book is a valuable tool for accountants, advisors, lawyers, public officials and anyone working in the sector.

This study of entrepreneurship in Europe is a greatly expanded and updated version, in English, of the author's thesis published in Dutch in 1996. Its analysis focuses on "bottlenecks" and cross-border problems confronting European entrepreneurs in the areas of income tax, corporate income tax, and value-added tax. Four countries are chosen as representative of all the tax systems existing within the EC: The Netherlands, Germany, France and the United Kingdom. The author spares no detail in his examination, explaining such important elements and distinctions as the following: how the entrepreneur is viewed under the varying tax regimes and in the different countries; entrepreneurship and the professions; incentives; sources of income; partnerships; companies and shareholders; calculation of taxable profit; justification for a separate corporate income tax; taxation of foundations and societies; and the possibility of fiscal unity among Member States for VAT purposes.

Beginning in the 1860s, the Russian Empire replaced a poll tax system that originated with Peter the Great with a modern system of income and excise taxes. Russia began a transformation of state fiscal power that was also underway across Western Europe and North America. States of Obligation is the first sustained study of the Russian taxation system, the first to study its European and transatlantic context, and the first to expose the essential continuities between the fiscal practices of the Russian Empire and the Soviet Union.

Using a wealth of materials from provincial and local archives across Russia, Yanni Kotsonis examines how taxation was simultaneously a revenue-raising and a state-building tool, a claim on the person and a way to produce a new kind of citizenship. During successive political, wartime, and revolutionary crises between 1855 and 1928, state fiscal power was used to forge social and financial unity and fairness and a direct relationship with individual Russians. State power eventually overwhelmed both the private sector economy and the fragile realm of personal privacy. States of Obligation is at once a study in Russian economic history and a reflection on the modern state and the modern citizen.

This book highlights China's engagement with Africa through trade, investment and financial linkages. Its three main goals are as follows: firstly, to provide insights into Chinese FDI in Africa, by exploring a range of infrastructural projects and several countries' historical, geographical, socio-political, cultural and economic backgrounds; secondly, to present the main double taxation treaties with Beijing and country profiles of the African economies; and lastly, to provide a valuable business guide for recognizing and capitalizing on new opportunities in Afro-Eurasia.

This volume presents contributions that analyse the extraordinary impact of digital technology on business, services, and the production of value in many sectors of the economy. At the heart of this book is the fact that the entire digital economy is now worth almost 6% of global GDP, and it continues to grow at an unprecedented rate. The volume covers the general debate on taxation and the digital economy with the chapters by Russo, Makiyama and Boccia, before completing the analysis with discussion of three national case studies covering the U.S. (Pagano), U.K. (Leonardi) and Italy (Boccia and Leonardi). Contributors are leading experts in the fields of taxation and the digital economy and contextualise the key issues surrounding the digitalisation of the economy from an international perspective.

Multinational corporations face different tax systems in different countries that require careful tax planning. A systematic approach is needed to minimize and avoid unnecessary business taxes. Some core issues of international taxation are part of a successful corporate tax plan in an international context. The first issue is a good understanding and appreciation of the principles of international taxation that include the different philosophies of taxation, the different kinds of taxes, the different tax systems, the different tax treaties and potential tax havens. The second issue is a thorough understanding of U.S. taxation of foreign income to avoid double taxation and the computation of foreign tax credits. The third issue is the choice of a transfer pricing method and the compliance with tax regulations on both the transfer of tangible and intangible assets. The fourth issue is the intelligent use of tax vehicles for exporting which can generate substantial savings and reduce the effective tax rate and involve the choice between the interest-charge domestic international sales corporation and the foreign sales corporation. A final issue is the efficient use of value-added taxation for activities taking place outside the U.S., and a new appreciation of the potential of this form of taxation for the United States. Practicing accountants, academics, business executives, students, legislators, and others who want a better understanding of the complex issues of international taxation will be interested in this book.

This book provides an analysis of the process and outcomes of the tax reform, with a focus on progressivity, redistribution, and inequality. Between 1977 and 1986, Spain underwent a comprehensive tax reform which shaped its fiscal system until today. It was made in connection with the transition to democracy and indeed was understood as a fundamental part of the political change. The book situates the reform both within Spanish history and international trends in tax systems and connects it to the expansion of the welfare state and regional decentralization in Spain. The analysis reveals that the tax system failed to attain progressivity, and significant levels of fraud had a noticeable impact on inequality. Because of this, fiscal redistribution remained limited. In the new political economy of the second globalization, late democratic and fiscal transitioners were unable to emulate the path of the welfare state forerunners.

The US tax and reporting rules applicable to foreign trusts - principally embodied as Subchapter J of the Internal Revenue Code of 1986, as amended - are notoriously complex. Now, with this volume, anyone who has to deal with these rules can find their use and meaning clearly explained, and proceed confidently to the best outcome in any situation where they apply. This guide covers all the following topics in detail: regular nongrantor (or accumulation) trusts of both the "simple" variety and the "complex" type with its challenging "throwback" rules and interest charge on accumulation distributions; the circumstances under which certain foreign trusts, such as section 672(f) (barring the application of the normal grantor trust rules to certain foreign trusts), section 643(h) (relating to distributions by certain foreign trusts through nominees), and section 643(i) (relating to loans from foreign trusts); reporting and penalty provisions and the accompanying IRS forms; and special issues, such as those surrounding incoming immigrants and outgoing expatriates. The book provides modified versions of the principal IRS forms (3520, 3520-A, 4970, 1040NR, and 1041) that are commonly filed for foreign trusts. These modifications, which scrupulously follow all applicable IRS rules, are much easier to use than the actual forms for the purpose of foreign trusts. Numerous examples throughout the book clarify the valid procedures and alternatives available at every point, a feature particularly useful in applying provisions that still await settled regulation and case law. Compliance issues that may arise on IRS audit are also examined. Professionals and advisors in law, tax, accounting, banking, and securities; settlers and beneficiaries; and students and academics both within and outside the United States should find this an informative and useful volume.

This book showcases the practical insights of some of Europe's foremost tax advisers and lawyers on recent case law issuing from the European Court of Justice. It also provides readers with informed analysis on how the Court may rule on future controversies impacting direct taxation.This timely and useful resource will examine each of the following topics, inter alia: CFC Legislation and Abuse of Law in the Community; free movement of capital and non-member countries; consequences for direct taxation; striking a proper balance between the national fiscal interests and the community interest; a perpetual struggle; personal income taxation of non-residents and the increasing impact of the EC Treaty Freedoms; why the European Court of Justice should interpret directly applicable Community law as a right to most-favoured nation treatment and a prohibition of double taxation; fiscal cohesion, fiscal territoriality, and Preservation of the (Balanced) Allocation of Taxing Power; what is the difference? limitation of the Temporal Effects of Judgments of the ECJ; Tax Facilities for State-induced Costs under the State Aid Rules; and EU Law and rules of tax procedure.

The tax system profoundly affects countless aspects of private behavior. It is a powerful policy influence on the distribution of income and it is the one aspect of government that almost every citizen cannot avoid. With tax reform high on the political agenda, this book brings together studies of leading tax economists and lawyers to assess the various reform proposals and examine the effects of tax reform in several distinct areas. Together, these studies and comments on them present a balanced evaluation of professional opinion on the issues that will be critical in the tax reform debate. The book addresses annual and lifetime distributional effects, saving, investment, transitional problems, simplification, home ownership and housing prices, charitable groups, international taxation, financial intermediaries and insurance, labor supply, and health insurance. In addition to Henry Aaron and William Gale, the contributors include Alan Auerbach, University of California, Berkeley; David Bradford, Princeton University; Charles Clotfelter, Duke University; Eric Engen, Federal Reserve; Don Fullerton, University of Texas; Jon Gruber, Massachusetts Institute of Technology; Patric Hendershott, Ohio State; David Ling, University of Florida; Ronald Perlman, Covington & Burling; Diane Lim Rogers, Congressional Budget Office; John Karl Scholz, University of Wisconsin; Joel Slemrod, University of Michigan; and Robert Triest, University of California, Davis.

This book provides an insight into commercial relations between large economies and Small States, the benefits of regional integration, the role of Small States as financial centres as well as B2B and State to State dispute resolution involving Small States. Several contributions allow the reader to familiarise themselves with the general subject matter; others scrutinise the particular issues Small States face when confronted with an international dispute and discuss new and innovative solutions. These solutions range from inventive ideas to help economic growth to appropriate mechanisms of dispute resolution including inter-State dispute resolution and specific areas of arbitration such as tax arbitration. Researchers, policy advisors and practitioners will find a wealth of insights, information and practical ideas in this book.

What are the implications and likelihood of reform of the income tax system in the United States—specifically, the expansion and scope of the tax "expenditure" (loophole) system embedded in the income tax codes? This book details the tax system that now provides for more than 200 tax expenditures, highlighting the potential lost tax dollars. Income tax policy and politics is an inherently complex and potentially confusing topic. This book makes the tax loophole system understandable for those without in-depth knowledge about taxes. It explains what our tax system looks like, why it is set up as it is, and what effects it has on raising revenue (and thus deficits) and the furtherance of other policy goals. Additionally, it explains why, despite popular and political desires, a significant overhaul of the tax system is very unlikely to be enacted: because tax expenditures (otherwise known as loopholes) benefit all Americans in some way and are supported as policy by both political parties. Written by John F. Witte, an established expert in tax policy and policy analysis, the book provides a balanced viewpoint that discusses the implications of reform of the income tax system in the United States, demonstrates the range of individuals who are affected by various provisions, and identifies what effects loopholes have on policy goals. Readers will see how both political parties are responsible for the creation and expansion of various loopholes, understand why many of these provisions make sound policy sense, and grasp how the tax code is affected by political desires and policy goals.

Third countries are not bound by European law; however, saying that EU Member States are not bound by European law in their relations with third countries would be incorrect. The judicial developments of European tax law based on the application of fundamental freedoms by the European Court of Justice has turned relations with third countries into one of the most controversial areas of European tax law, giving rise to a significant degree of legal uncertainty. The first waves of direct tax cases decided by the ECJ on the relations with third countries have not entirely solved the main critical issues arising in such context, including the ones involving the external scope of fundamental freedoms. Consequently, the expert analysis contained in this book will be of significant interest to many international tax practitioners and academics throughout the world.
Among the vitally important areas this book addresses...
- The external scope of Article 56 EC Treaty and its impact on the relations with third countries
- The indirect impact of other fundamental freedoms on the relations with third countries
- The scope of fundamental freedoms in relations to EEA States under the EEA Agreement
- The relations with other third countries in the field of direct taxes (including, among other, EPAs countries)
- The impact of the EU agreements on the direct tax relations between Switzerland and the EU Member States
- The impact of secondary EC law on the relations with third countries in the field of direct taxes
- The scope of Article 307 EC Treaty and its application in the field of direct taxes
- The external treaty making powers of the European Union in the field ofdirect taxes.

This book is open access under a CC BY 4.0 license. This book takes a taxpayer's perspective on the relations taxation creates between people and their state. Bjoerklund Larsen proposes that in order to understand tax compliance and cheating, we have to look beyond law, psychological experiments and surveys to also include tax collectors and taxpayers' practices. The text explores the view of taxes seen as citizen's explicit economic relation to the state and implicit economic relation to all other compatriots. Bjoerklund Larsen directs our gaze onto the concept of reciprocity, which is often proposed as an explanation in tax compliance research, and explores its diverse meanings and implications ethnographically. The empirical cases are based on ethnography from two opposing tax practices in Sweden. Firstly, from a study of analysts, auditors, legal experts and managers at the Swedish Tax Agency and how they, quite successfully, strive for legitimacy in their tax collecting activities. Secondly, from fieldwork among a group of middle-aged Swedes and how they justify their purchasing work off the books - essentially tax-cheating practices. Sweden is a modern welfare society with citizens holding rational and secular values, yet trusting their government and fellow citizens. Sweden also has a high tax burden that is collected by one of its most revered governmental agencies - the Swedish Tax Agency - making it an interesting case studying tax compliance.

This book analyzes shifting international taxation strategies in pursuit of tax nomads, individuals and companies who minimize their tax obligations among multiple countries. Focusing on the efforts of the United States, the collective endeavours of the European Union and the global initiative of the OECD under G20 guidance, it investigates their attempts to understand and control the mechanisms employed by such nomads. The author directs particular attention to intellectual property, used by multinational corporations to move income from high-tax to low-tax locations. Contrary to claims that globalization hinders tax collection, Vlcek argues that state sovereignty and state power remain the defining characteristic of international taxation. The EU and OECD in turn, he concludes, are leveraging cooperation with the US to force other countries to share taxpayer information with them. This significant work will interest economists, political scientists and tax experts.

This volume describes how various types of taxes such as VATs, corporate income taxes, retail sales taxes, and excise taxes are being modified to achieve environmental goals. The author gives particular focus to situations in which taxes are imposed on imports and where rebates are granted when domestic products are exported. These taxes are evaluated with respect to exceptions to GATT and how these exceptions can be used to create powerful tax initiatives even though they might be considered "GATT-illegal". The book shows how to integrate economically effective environmental taxes and tax subsidies with the major international trade treaties. Tax initiatives can be an important tool to improve the free trade system while at the same time combating environmental depredation. Manufacturers, exporters, tax and environmental policy makers, international trade and tax attorneys, and academics working in the fields of environmental regulation, trade policy, and taxation should find this work a provocative treatise on this topic.