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Controlled Foreign Corporation
Controlled foreign corporation (CFC) rules are features of an income tax system designed to limit artificial deferral of tax by using offshore low taxed entities. The rules are needed only with respect to income of an entity that is not currently taxed to the owners of the entity. Generally, certain classes of taxpayers must include in their income currently certain amounts earned by foreign entities they or related persons control. A set of rules generally defines the types of owners and entities affected, the types of income or investments subject to current inclusion, exceptions to inclusion, and means of preventing double inclusion of the same income. Countries with CFC rules include the United States (since 1962), the United Kingdom, Germany, Japan, Australia, New Zealand, Brazil, Russia (since 2015), Sweden, and many others. Rules in different countries may vary significantly. Motivations The tax law of many countries, including the United States, does normally not tax a sh ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Income Tax
An income tax is a tax imposed on individuals or entities (taxpayers) in respect of the income or profits earned by them (commonly called taxable income). Income tax generally is computed as the product of a tax rate times the taxable income. Taxation rates may vary by type or characteristics of the taxpayer and the type of income. The tax rate may increase as taxable income increases (referred to as graduated or progressive tax rates). The tax imposed on companies is usually known as corporate tax and is commonly levied at a flat rate. Individual income is often taxed at progressive rates where the tax rate applied to each additional unit of income increases (e.g., the first $10,000 of income taxed at 0%, the next $10,000 taxed at 1%, etc.). Most jurisdictions exempt local charitable organizations from tax. Income from investments may be taxed at different (generally lower) rates than other types of income. Credits of various sorts may be allowed that reduce tax. Some jurisdicti ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Deferral
Tax deferral refers to instances where a taxpayer can delay paying taxes to some future period. In theory, the net taxes paid should be the same. Taxes can sometimes be deferred indefinitely, or may be taxed at a lower rate in the future, particularly for deferral of income taxes. Corporate tax deferral Corporations (or other enterprises) may often be allowed to defer taxes, for example, by using accelerated depreciation. Profit taxes (or other taxes) are reduced in the current period by either lowering declared revenue now, or by increasing expenses. In principle, taxes in future periods should be higher. Income tax deferral In many jurisdictions, income taxes may be deferred to future periods by a number of means. For example, income may be recognized in future years by using income tax deductions, or certain expenses may be provided as deductions in current rather than future periods. A 2010 study documents the large extent to which U.S. taxpayers accelerate their deductible sta ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Offshore Financial Centre
An offshore financial centre (OFC) is defined as a "country or jurisdiction that provides financial services to nonresidents on a scale that is incommensurate with the size and the financing of its domestic economy." "Offshore" does not refer to the location of the OFC, since many Financial Stability Forum– IMF OFCs, such as Delaware, South Dakota, Singapore, Luxembourg and Hong Kong, are located "onshore", but to the fact that the largest users of the OFC are non-resident, i.e. "offshore". The IMF lists OFCs as a third class of financial centre, with international financial centres (IFCs), and regional financial centres (RFCs); there is overlap (e.g. Singapore is an RFC and an OFC). The Caribbean, including the Cayman Islands, the British Virgin Islands and Bermuda, has several major OFCs, facilitating many billions of dollars worth of trade and investment globally. During April–June 2000, the Financial Stability Forum–International Monetary Fund produced the first l ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Transfer Pricing
In taxation and accounting, transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm’s length (the arm’s-length principle). The OECD and World Bank recommend intragroup pricing rules based on the arm’s-length principle, and 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative practice.World Bank pp. 35-51 Countries with transfer pricing legislation generally follow th''OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations''in most respects, although their rules can differ on some important details. Where adopted, transfe ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Internal Revenue Code
The Internal Revenue Code (IRC), formally the Internal Revenue Code of 1986, is the domestic portion of federal statutory tax law in the United States, published in various volumes of the United States Statutes at Large, and separately as Title 26 of the United States Code (USC). It is organized topically, into subtitles and sections, covering income tax in the United States, payroll taxes, estate taxes, gift taxes, and excise taxes; as well as procedure and administration. The Code's implementing federal agency is the Internal Revenue Service. Origins of tax codes in the United States Prior to 1874, U.S. statutes (whether in tax law or other subjects) were not codified. That is, the acts of Congress were not separately organized and published in separate volumes based on the subject matter (such as taxation, bankruptcy, etc.). Codifications of statutes, including tax statutes, undertaken in 1873 resulted in the Revised Statutes of the United States, approved June 22, 1874, eff ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Department Of The Treasury
The Department of the Treasury (USDT) is the national treasury and finance department of the federal government of the United States, where it serves as an executive department. The department oversees the Bureau of Engraving and Printing and the U.S. Mint. These two agencies are responsible for printing all paper currency and coins, while the treasury executes its circulation in the domestic fiscal system. The USDT collects all federal taxes through the Internal Revenue Service; manages U.S. government debt instruments; licenses and supervises banks and thrift institutions; and advises the legislative and executive branches on matters of fiscal policy. The department is administered by the secretary of the treasury, who is a member of the Cabinet. The treasurer of the United States has limited statutory duties, but advises the Secretary on various matters such as coinage and currency production. Signatures of both officials appear on all Federal Reserve notes. The depart ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
De Minimis
''De minimis'' is a Latin expression meaning "pertaining to minimal things", normally in the terms ''de minimis non curat praetor'' ("The praetor does not concern himself with trifles") or ''de minimis non curat lex'' ("The law does not concern itself with trifles"), a legal doctrine by which a court refuses to consider trifling matters. Queen Christina of Sweden (r. 1633–1654) favoured the similar Latin adage, ''aquila non capit muscās'' (the eagle does not catch flies). The legal history of ''de minimis'' dates back to the 15th century. The general term has come to have a variety of specialised meanings in various contexts as shown below, which indicate that beneath a certain low level a quantity is regarded as trivial, and treated commensurately. Examples of application of the ''de minimis'' rule Taxation Under U.S. tax rules, the ''de minimis'' rule governs the treatment of small amounts of market discount. Under the rule, if a bond is purchased with a small a ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Income And Corporation Taxes Act 1988
Income is the consumption and saving opportunity gained by an entity within a specified timeframe, which is generally expressed in monetary terms. Income is difficult to define conceptually and the definition may be different across fields. For example, a person's income in an economic sense may be different from their income as defined by law. An extremely important definition of income is Haig–Simons income, which defines income as ''Consumption + Change in net worth'' and is widely used in economics. For households and individuals in the United States, income is defined by tax law as a sum that includes any wage, salary, profit, interest payment, rent, or other form of earnings received in a calendar year.Case, K. & Fair, R. (2007). ''Principles of Economics''. Upper Saddle River, NJ: Pearson Education. p. 54. Discretionary income is often defined as gross income minus taxes and other deductions (e.g., mandatory pension contributions), and is widely used as a basis to com ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
HM Revenue And Customs
HM Revenue and Customs (His Majesty's Revenue and Customs, or HMRC) is a non-ministerial government department, non-ministerial Departments of the United Kingdom Government, department of the His Majesty's Government, UK Government responsible for the tax collection, collection of Taxation in the United Kingdom, taxes, the payment of some forms of Welfare state in the United Kingdom, state support, the administration of other regulatory Regime#Politics, regimes including the national minimum wage and the issuance of national insurance numbers. HMRC was formed by the merger of the Inland Revenue and HM Customs and Excise, which took effect on 18 April 2005. The department's logo is the St Edward's Crown enclosed within a circle. Prior to the Elizabeth II, Queen's death on 8 September 2022, the department was known as ''Her'' Majesty's Revenue and Customs and has since been amended to reflect the change of monarch. Departmental responsibilities The department is responsible for the ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Foreign Personal Holding Company
Foreign personal holding company income (FPHCI) is defined for U.S. controlled foreign corporation rules and, with modifications, for U.S. foreign tax credit rules. It consists of interest, dividends, rents, royalties, gains on property producing FPHCI, and certain other items. Exceptions are provided for active rents and royalties, certain related party rents and royalties, same country income, and certain other items. For purposes of the foreign tax credit, an additional exception requires look-through of certain income received from a controlled foreign corporation. Exceptions Under the basic definition, there are exclusions and exceptions, which include: *Rents and royalties derived in the active conduct of a trade or business (e.g., a car rental business). For royalties to qualify, the property must have been substantially developed by the recipient of the royalties. *Interest and dividends received from related parties organized in the same country as the recipient. *Rents ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Japan
Japan ( ja, 日本, or , and formally , ''Nihonkoku'') is an island country in East Asia. It is situated in the northwest Pacific Ocean, and is bordered on the west by the Sea of Japan, while extending from the Sea of Okhotsk in the north toward the East China Sea, Philippine Sea, and Taiwan in the south. Japan is a part of the Ring of Fire, and spans Japanese archipelago, an archipelago of List of islands of Japan, 6852 islands covering ; the five main islands are Hokkaido, Honshu (the "mainland"), Shikoku, Kyushu, and Okinawa Island, Okinawa. Tokyo is the Capital of Japan, nation's capital and largest city, followed by Yokohama, Osaka, Nagoya, Sapporo, Fukuoka, Kobe, and Kyoto. Japan is the List of countries and dependencies by population, eleventh most populous country in the world, as well as one of the List of countries and dependencies by population density, most densely populated and Urbanization by country, urbanized. About three-fourths of Geography of Japan, the c ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Passive Foreign Investment Company
For purposes of income tax in the United States, U.S. persons owning shares of a passive foreign investment company (PFIC) may choose between (i) current taxation on the income of the PFIC or (ii) deferral of such income subject to a deemed tax and interest regime. The provision was enacted as part of the Tax Reform Act of 1986 as a way of placing owners of offshore investment funds on a similar footing to owners of U.S. investment fundsregulated investment companies. The original provisions applied for all foreign corporations meeting either an income or an asset test. However, 1997 amendments limited the application in the case of U.S. Shareholders of controlled foreign corporations. Definition Any foreign (i.e., non-U.S.) corporation meeting either the income test or the asset test is a PFIC with respect to each shareholder when the test is met. PFIC status applies separately for each U.S. person owning shares, and also separately with respect to shares acquired at different ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
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