Download Anglo-American Corporate Taxation: Tracing the Common Roots by Steven A. Bank PDF

By Steven A. Bank

The united kingdom and the united states have traditionally represented contrary ends of the spectrum of their techniques to taxing company source of revenue. less than the British technique, company and shareholder source of revenue taxes were built-in below an imputation method, with tax paid on the company point imputed to shareholders via a whole or partial credits opposed to dividends obtained. less than the yank procedure, in contrast, company and shareholder source of revenue taxes have remained separate lower than what's known as a 'classical' approach within which shareholders obtain very little aid from a moment layer of taxes on dividends. Steven A. financial institution explores the evolution of the company source of revenue tax structures in each one nation throughout the 19th and 20th centuries to appreciate the typical criminal, monetary, political and cultural forces that produced such divergent methods and explains why convergence could be most probably sooner or later as every one state grapples with company taxation in an period of globalization.

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1196 (1862). , 1534. , 1527 (statement of Rep. Sherman) (proposing to exempt mortgages from tax because of concerns about double taxation). , 1486 (statement of Rep. , 1545 (statement of Rep. , 2555 (statement of Sen. , 2573 (proposed integration scheme offered by Sen. Howe). Act of July 1, 1862, ch. 119, § 91, 12 Stat. at 473–4 (1862). 2 united states 33 shareholders with incomes below $600. ”94 Nevertheless, it produced some inequities. Individuals with incomes in excess of $10,000 would be taxed at 3 percent on dividends or interest from railroads and other such corporations, but at 5 percent on all other income.

132. Section 59 of the House bill provided, in relevant part, [t]hat there shall be levied and collected a tax of 2 per cent on all dividends in scrip or money thereafter declared due, wherever and whenever the same be declared payable to stockholders, policy holders, or depositors or parties whatsoever, including nonresidents, whether citizens or aliens, as part of the earnings, income or gains of any bank, trust company, savings institution, and of any fire, marine, life, inland insurance company, either stock or mutual, under whatever name or style known or called in the United States or Territories, whether specially incorporated or existing under general laws, and on all undistributed sums, or sums made or added during the year to their surplus or contingent funds.

95 While the latter problem was controversial,96 albeit rare in occurrence given the low proportion of income tax revenues attributable to the dividend provisions,97 the former problem was partially alleviated by administrative practice. George S. 98 The 1862 Act did appear to impose a separate tax upon certain corporations in the form of a gross receipts tax. 101 94 95 96 97 98 99 101 Smith, The United States Federal Internal Tax History, p. 55. Hill, “The Civil War Income Tax,” 427–8. See Harold Langenderfer, The Federal Income Tax, 1861–1872 (New York: Arno Press, 1980), pp.

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