What is Double Tax Avoidance Agreement (DTAA)? The “Double Tax Avoidance Agreement (DTAA)” or “Tax Treaty” is essentially bilateral agreements entered into between two countries‚ in our case‚ between India and another foreign state. The basic objective is to avoid taxation of income in both the countries (i.e. Double taxation of same income). Currently India has comprehensive DTAA or Tax Treaty with 84 other countries. Let’s take an example to understand how DTAA works; AnNRI residing in ABC
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Issue Did the corporation violate section 38 of the tax Act? The case addresses a tax payer’s questions the constitutional validity of section 38 of the tax Act‚ Corporation Tax Act‚ enacted on August 5‚ 1909‚ against the corporation. Rule “The tax is to be equivalent to 1 per cent of the entire net [220 U.S. 107‚ 145] income over and above $5‚000 received by such corporation or company from all sources during the year‚ excluding‚ however‚ amounts received by them as dividends upon stock of
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True/false #1 Any distribution in excess of E & P is treated as a tax-free recovery of capital by shareholders. ANS: F Distributions in excess of E & P are a tax-free recovery of capital to the extent of stock basis. Distributions in excess of basis trigger recognition of capital gain. #21 A corporation that distributes a property dividend must reduce its E & P by the fair market value of the property less any liability on the property. ANS: F E & P must be reduced by the greater of the adjusted
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The Wall Street Journal: The article titled “The Corporate Tax Political Drive” talks about American companies moving over sees because they feel as if they are being punished by taxes for investing over sees. If a company invests over sees they have to pay the taxes over there‚ the author would say is rightfully so‚ and they would additionally have to pay the taxes her‚ not rightfully so. The newspaper takes the side that it is not right to have to pay both sets of taxes and I believe that news
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when a new corporation is formed or may reflect additional capital contributions to an existing corporation. Without Section 351‚ a sole proprietorship or a partnership would have difficulty adopting the corporate form of organization for legal and/or tax purposes because the transfer of appreciated property would constitute a taxable transaction in a recognized gain. The deferral of gain or loss under Section 351 can be justified because the assets have merely been transferred to a corporation that
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PERSONAL COPY/ NOT FOR SALE OR CIRCULATION (Session 2012-13) INTRODUCTION HISTORY OF INCOME-TAX: 1. India’ trust with income tax dates back to 1859 when James Wilson‚ Finance member in the Council of India‚ came to the country to establish the tax structure‚ a new paper currency and to remodel the finance system. 2. A bill imposing tax on profits from property‚ professions‚ trades and offices was passed by the Legislative Council of India. It received the assent of the Governor General on July
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History Income tax levels in India were very high during 1950-1980‚ in 1970-71 there were 11 tax slabs with highest tax rate being 93.5% including surcharges. In 1973-74 highest rate was 97.5%. But to reduce tax evasion tax rates were reduced later on‚ by "1992-93" maximum tax rates were reduced to 40%. [2][3] [edit]Residential status‚ Scope of taxable income & Charge [edit]Charge to Income-tax Whose income exceeds the maximum amount‚ which is not chargeable to the income tax‚ is an assesse
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INCOME TAX NOTES Residential Status and Incidence of Tax According to Section 5 of the Income Tax Act the scope of total Income of an assessee depends on his residential status.On the basis of residential status assessee are classified under the following two categories: 1. Resident 2. Non-resident. As per as resident individuals and Hindu Undivided Families are concerned‚ they can be further divided into two categories: 1. Ordinarily Resident 2. Not ordinarily Resident. Residential
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UK Tax System. The taxation structure which any country imposes has a direct impact on its accumulation and redistribution of wealth within its economy. The UK tax system is administered by Her Majesty Revenue and Custom (HMRC) and comprises of a number of taxes. Tax is collected directly or indirectly. Direct taxation is based on income and profits made by an individual. With the direct taxation‚ the taxpayer pays his tax directly to the government. Examples of direct taxes include income tax
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Tax Research Memo http://www2.gsu.edu/~accerl/home.html Your Firm October 19‚ 2011 Relevant Facts Joe‚ CPA reimburses a client for a $75‚000 tax liability that is traceable to Joe’s ineffective tax advice. For fear of increasing his malpractice premiums‚ Joe decides not to file a claim with his insurance company. Specific Issues How much‚ if any‚ of the $75‚000 paid to the client can Joe deduct using either causality loss or business expense? Conclusions Joe may not deduct
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