By Steven A. Bank
The united kingdom and the united states have traditionally represented contrary ends of the spectrum of their ways to taxing company source of revenue. below the British process, company and shareholder source of revenue taxes were built-in less than an imputation method, with tax paid on the company point imputed to shareholders via an entire or partial credits opposed to dividends bought. below the yank procedure, against this, company and shareholder source of revenue taxes have remained separate lower than what's referred to as a 'classical' method within which shareholders obtain very little reduction from a moment layer of taxes on dividends. Steven A. financial institution explores the evolution of the company source of revenue tax platforms in each one nation throughout the 19th and 20th centuries to appreciate the typical criminal, fiscal, political and cultural forces that produced such divergent methods and explains why convergence might be most probably sooner or later as every one kingdom grapples with company taxation in an period of globalization.
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Extra info for Anglo-American Corporate Taxation: Tracing the Common Roots of Divergent Approaches (Cambridge Tax Law Series)
113 109 110 111 112 113 See United States Internal Revenue Service, Digest of Decisions and Regulations Made by the Commissioner of Internal Revenue Under Various Acts of Congress Relating to Internal Revenue, and Abstracts of Judicial Decisions, and Opinions of AttorneysGeneral, as to Internal-Revenue Cases. From December 24, 1864, to June 13, 1898. (Washington, DC: Government Printing Ofﬁce, 1906), pp. 16, 36, 37, 39, and 40. Although the principal challenges surrounding this provision applied to corporate proﬁts, the provision actually applied to the undistributed proﬁts of both corporations and partnerships.
P. 5098 (statement of Sen. Lodge). , p. 5099 (statement of Sen. Spooner). Act of June 13, 1898, ch. 448, 30 Stat. 448. See “Voted to tax trusts” Washington Post, June 2, 1898, p. 4A. As ﬁrst proposed, the tax would have been levied on other industries as well, including transportation and public utility corporations. The Commercial and Financial Chronicle was indignant at the singling out of these industries, calling it “an odd proposal. It would seem difﬁcult to say on just what principle the selections for taxation named in the proposed amendment were made.
Eventually, the Supreme Court considered the issue in The Collector v. 111 Thus, regardless of a business’s form of organization, its owners were taxed on a conduit basis. Congress’s decision to refrain from levying a separate entity-level tax on corporations and to instead tax both corporate and partnership income to their owners on a pass-through basis was not simply a product of the contemporary understanding of the corporation. 112 Moreover, the view of corporations in the courts would have permitted an entity-level tax.
Anglo-American Corporate Taxation: Tracing the Common Roots of Divergent Approaches (Cambridge Tax Law Series) by Steven A. Bank