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Formulary Apportionment
Formulary apportionment, also known as unitary taxation, is a method of allocating profit earned (or loss incurred) by a corporation or corporate group to a particular tax jurisdiction in which the corporation or group has a taxable presence. It is an alternative to separate entity accounting, under which a branch or subsidiary within the jurisdiction is accounted for as a separate entity, requiring prices for transactions with other parts of the corporation or group to be assigned according to the arm's length standard commonly used in transfer pricing. In contrast, formulary apportionment attributes the corporation's total worldwide profit (or loss) to each jurisdiction, based on factors such as the proportion of sales, assets or payroll in that jurisdiction. When applied to a corporate group, formulary apportionment requires combined reporting of the group's results. The parent and all of its subsidiaries are viewed as though they were a single entity (''unitary combination''), ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Arm's Length Principle
The arm's length principle (ALP) is the condition or the fact that the parties of a transaction are independent and on an equal footing. Such a transaction is known as an "arm's-length transaction". It is used specifically in contract law to arrange an agreement that will stand up to legal scrutiny, even though the parties may have shared interests (e.g., employer-employee) or are too closely related to be seen as completely independent (e.g., the parties have familial ties). An arm's length relationship is distinguished from a fiduciary relationship, where the parties are not on an equal footing, but rather, power and information asymmetries exist. It is also one of the key elements in international taxation as it allows an adequate allocation of profit taxation rights among countries that conclude double tax conventions, through transfer pricing, among each other. Transfer pricing and the arm's length principle was one of the focal points of the Base Erosion and Profit Shif ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Internal Revenue Service
The Internal Revenue Service (IRS) is the revenue service for the United States federal government, which is responsible for collecting U.S. federal taxes and administering the Internal Revenue Code, the main body of the federal statutory tax law. It is an agency of the Department of the Treasury and led by the Commissioner of Internal Revenue, who is appointed to a five-year term by the President of the United States. The duties of the IRS include providing tax assistance to taxpayers; pursuing and resolving instances of erroneous or fraudulent tax filings; and overseeing various benefits programs, including the Affordable Care Act. The IRS originates from the Commissioner of Internal Revenue, a federal office created in 1862 to assess the nation's first income tax to fund the American Civil War. The temporary measure provided over a fifth of the Union's war expenses before being allowed to expire a decade later. In 1913, the Sixteenth Amendment to the U.S. Constitutio ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Brookings Institution
The Brookings Institution, often stylized as simply Brookings, is an American research group founded in 1916. Located on Think Tank Row in Washington, D.C., the organization conducts research and education in the social sciences, primarily in economics (and tax policy), metropolitan policy, governance, foreign policy, global economy, and economic development. Its stated mission is to "provide innovative and practical recommendations that advance three broad goals: strengthen American democracy; foster the economic and social welfare, security and opportunity of all Americans; and secure a more open, safe, prosperous, and cooperative international system." Brookings has five research programs at its Washington campus: Economic Studies, Foreign Policy, Governance Studies, Global Economy and Development, and Metropolitan Policy. It also established and operated three international centers in Doha, Qatar (Brookings Doha Center); Beijing, China (Brookings-Tsinghua Center for Public P ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Consolidation
Tax consolidation, or combined reporting, is a regime adopted in the tax or revenue legislation of a number of countries which treats a group of wholly owned or majority-owned companies and other entities (such as trusts and partnerships) as a single entity for tax purposes. This generally means that the head entity of the group is responsible for all or most of the group's tax obligations (such as paying tax and lodging tax returns). Consolidation is usually an all-or-nothing event: once the decision to consolidate has been made, companies are irrevocably bound. Only by having less than a 100% interest in a subsidiary can that subsidiary be left out of the consolidation. The aim of a tax consolidation regime is to reduce administrative costs for government revenue departments and reduce compliance costs for corporate taxpayers. For companies, consolidating can help understate profits by having losses in one group company reduce profits for another. Assets can be transferred betwee ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Combined Reporting
Tax consolidation, or combined reporting, is a regime adopted in the tax or revenue legislation of a number of countries which treats a group of wholly owned or majority-owned companies and other entities (such as trusts and partnerships) as a single entity for tax purposes. This generally means that the head entity of the group is responsible for all or most of the group's tax obligations (such as paying tax and lodging tax returns). Consolidation is usually an all-or-nothing event: once the decision to consolidate has been made, companies are irrevocably bound. Only by having less than a 100% interest in a subsidiary can that subsidiary be left out of the consolidation. The aim of a tax consolidation regime is to reduce administrative costs for government revenue departments and reduce compliance costs for corporate taxpayers. For companies, consolidating can help understate profits by having losses in one group company reduce profits for another. Assets can be transferred betwee ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Exchange Rate
In finance, an exchange rate is the rate at which one currency will be exchanged for another currency. Currencies are most commonly national currencies, but may be sub-national as in the case of Hong Kong or supra-national as in the case of the euro. The exchange rate is also regarded as the value of one country's currency in relation to another currency. For example, an interbank exchange rate of 114 Japanese yen to the United States dollar means that ¥114 will be exchanged for or that will be exchanged for ¥114. In this case it is said that the price of a dollar in relation to yen is ¥114, or equivalently that the price of a yen in relation to dollars is $1/114. Each country determines the exchange rate regime that will apply to its currency. For example, a currency may be floating, pegged (fixed), or a hybrid. Governments can impose certain limits and controls on exchange rates. Countries can also have a strong or weak currency. There is no agreement in the econ ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Accounting
U.S. tax accounting refers to accounting for tax purposes in the United States. Unlike most countries, the United States has a comprehensive set of accounting principles for tax purposes, prescribed by tax law, which are separate and distinct from Generally Accepted Accounting Principles. Basic rules The Internal Revenue Code governs the application of tax accounting.Section 446sets the basic rules for tax accounting. Tax accounting undeemphasizes consistency for a tax accounting method with references to the applied financial accounting to determine the proper method. The taxpayer must choose a tax accounting method using the taxpayer's financial accounting method as a reference point. Types of tax accounting methods Proper accounting methods are described iwhich permits cash, accrual, and other methods approved by the Internal Revenue Service (IRS) including combinations. After choosing a tax accounting method, undesection 446(b)the IRS has wide discretion to re-compute th ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Taxable Profit
Taxable income refers to the base upon which an income tax system imposes tax. In other words, the income over which the government imposed tax. Generally, it includes some or all items of income and is reduced by expenses and other deductions. The amounts included as income, expenses, and other deductions vary by country or system. Many systems provide that some types of income are not taxable (sometimes called non-assessable income) and some expenditures not deductible in computing taxable income. Some systems base tax on taxable income of the current period, and some on prior periods. Taxable income may refer to the income of any taxpayer, including individuals and corporations, as well as entities that themselves do not pay tax, such as partnerships, in which case it may be called “net profit”. Most systems require that all income realized (or derived) be included in taxable income. Some systems provide tax exemption for some types of income. Many systems impose tax a ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Compliance Costs
A tax is a compulsory financial charge or some other type of levy imposed on a taxpayer (an individual or legal entity) by a governmental organization in order to fund government spending and various public expenditures (regional, local, or national), and tax compliance refers to policy actions and individual behaviour aimed at ensuring that taxpayers are paying the right amount of tax at the right time and securing the correct tax allowances and tax reliefs. The first known taxation took place in Ancient Egypt around 3000–2800 BC. A failure to pay in a timely manner ( non-compliance), along with evasion of or resistance to taxation, is punishable by law. Taxes consist of direct or indirect taxes and may be paid in money or as its labor equivalent. Most countries have a tax system in place, in order to pay for public, common societal, or agreed national needs and for the functions of government. Some levy a flat percentage rate of taxation on personal annual income, but mos ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Double Taxation
Double taxation is the levying of tax by two or more jurisdictions on the same income (in the case of income taxes), asset (in the case of capital taxes), or financial transaction (in the case of sales taxes). Double liability may be mitigated in a number of ways, for example, a jurisdiction may: * exempt foreign-source income from tax, * exempt foreign-source income from tax if tax had been paid on it in another jurisdiction, or above some benchmark to exclude tax haven jurisdictions, or * fully tax the foreign-source income but give a credit for taxes paid on the income in the foreign jurisdiction. Jurisdictions may enter into tax treaties with other countries, which set out rules to avoid double taxation. These treaties often include arrangements for exchange of information to prevent tax evasion such as when a person claims tax exemption in one country on the basis of non-residence in that country, but then does not declare it as foreign income in the other country; or who ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
California Franchise Tax Board
The California Franchise Tax Board (FTB) administers and collects state personal income tax and corporate franchise and income tax of California. It is part of the California Government Operations Agency. The board is composed of the California State Controller, the director of the California Department of Finance, and the chair of the California Board of Equalization. The chief administrative official is the executive officer of the Franchise Tax Board. History In 1879 California adopted its state constitution which among many other programs created the State Board of Equalization and the State Controller, which administered all tax programs.PublicationFranchise Tax Board at a Glance, page 2/ref> In 1929, the state legislature created the office of the Franchise Tax Commissioner to administer California’s Bank and Corporation Franchise Tax Act. In 1950, California abolished the office of the Franchise Tax Commissioner and created the Franchise Tax Board as it exists to ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Barclays Bank PLC
Barclays () is a British multinational universal bank, headquartered in London, England. Barclays operates as two divisions, Barclays UK and Barclays International, supported by a service company, Barclays Execution Services. Barclays traces its origins to the goldsmith banking business established in the City of London in 1690. James Barclay became a partner in the business in 1736. In 1896, twelve banks in London and the English provinces, including Goslings Bank, Backhouse's Bank and Gurney, Peckover and Company, united as a joint-stock bank under the name Barclays and Co. Over the following decades, Barclays expanded to become a nationwide bank. In 1967, Barclays deployed the world's first cash dispenser. Barclays has made numerous corporate acquisitions, including of London, Provincial and South Western Bank in 1918, British Linen Bank in 1919, Mercantile Credit in 1975, the Woolwich in 2000 and the North American operations of Lehman Brothers in 2008. Barclays has a pr ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
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