FACULTY OF LAW Lund University Sabina Örberg Tax Planning with Holding Companies for US Investors in Europe A Comparative Study of Holding Regimes in Sweden and Switzerland JAEM03 Master Thesis European Business Law 30 higher education credits Supervisor: Mats Tjernberg Term: Spring 2013 Contents SUMMARY 1 SAMMANFATTNING 2 PREFACE 3 ABBREVIATIONS 4 1 5 INTRODUCTION 1.1 Background 1.2 Purpose 7 1.3 Method and Material 7 1.4 Delimitations
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Tax Law Exam L. 2 Jurisdiction To Tax Basic Formula: S4-10 -Tax Payable = (Taxable Income x Tax rate) - Tax Offsets Taxable Year: 1 July – 30 June (note: s4-10 Note 1 – Commissioner may allow to adopt different period Taxable Income S4-15 – Taxable Income= Assessable Income – Deductions Assessable Income S6-1 – Assessable Income= • Ordinary Income S6-5 AND • Statutory Income s6-10 BUT NOT • Exempt Income s6-15 Deductions General Deductions -s8-1 Specific Deductions
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Chapter 10 Property: Dispositions SOLUTIONS MANUAL Discussion Questions: 1. [LO 1] Compare and contrast different ways in which a taxpayer triggers a realization event by disposing of an asset. A realization event for tax purposes is created in many ways. Virtually any disposal will result in a sale or other disposition. These include a sale‚ trade‚ gift to charity‚ disposal to the landfill‚ or destruction in a natural disaster. In a sale or trade (exchange)‚ the taxpayer receives something
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well-developed tax structure with clearly demarcated authority between Central and State Governments and local bodies. Central Government levies taxes on income (except tax on agricultural income‚ which the State Governments can levy)‚ customs duties‚ central excise and service tax. Value Added Tax (VAT)‚ (Sales tax in States where VAT is not yet in force)‚ stamp duty‚ State Excise‚ land revenue and tax on professions are levied by the State Governments. Local bodies are empowered to levy tax on properties
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The Justification for a Soft Drink Tax The Coca-Cola brand has built itself into a staple of American culture. This is a terrifying thought for public health advocates who see Coke and other soft drinks as being major culprits behind a growing national health crisis. Empirical evidence shows that over-consumption of soft drinks clearly causes harm to the individuals who consume them‚ however‚ the waging battle over soda legislation will not be won on the grounds of health alone. The argument that
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Value-Added Tax is a form of sales tax. It is a tax on consumption levied on the sale‚ barter‚ exchange or lease of goods or properties and services in the Philippines and on importation of goods into the Philippines. It is an indirect tax‚ which may be shifted or passed on to the buyer‚ transferee or lessee of goods‚ properties or services. 1. What is a VAT registered individual? * Any person or entity who‚ in the course of his trade or business‚ sells‚ barters‚ exchanges‚ leases goods
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Objectives of Lecture : At the end of this lecture‚ you should be able to: understand the ordinary concepts of income; | | THE ORDINARY CONCEPTS OF INCOME What is Income? The assessable income of an entity for a year of income includes the ordinary income of an entity and the statutory income of the entity for that year (Section 6-1 ITAA (1997)). Ordinary income is income according to ordinary concepts. The courts have had to determine what is income according to
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company‚ investors want to make sure the company is well managed. Because the differences between effective tax rates of companies of equal size that perform similar functions in the same geographical region are generally due to managerial decisions‚ a company with the lower effective tax rate could have the better administration and therefore be a better investment. The statutory corporate tax rate is the rate that is imposed on taxable income of corporations‚ which is equal to corporate receipts less
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1974‚ the tax year here at issue‚ RXL paid a dividend distribution to Xerox and paid the requisite ACT in the United Kingdom on the distribution. A portion of that ACT was set off in 1974 against RXL’s mainstream corporation tax in the United Kingdom. The foreign tax credit for that portion of the 1974 ACT is not in dispute. The portion of the ACT was not used to offset RXL’s mainstream tax was surrendered by RXL to its United Kingdom subsidiaries. The U.S IRS then withdrew the foreign tax credit for
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Corporate Tax Chapter 5: Complete Liquidations (Textbook: Corporate‚ Partnership‚ Estate and Gift Taxation (2013 Ed.) by Pratt‚ Kulsard) I. Introduction • Ch. 3 & 4: distributions of property and stock as well as those relating to redemptions and partial liquidations o Corp. continues to operate all or part of its business • Ch. 5: complete liquidation • Reasons: o Business’s profitability‚ or lack thereof‚ no longer justifies continuing the corp. o Shareholders simply seek the corp’s
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