Last edited by Kazijas
Thursday, July 30, 2020 | History

2 edition of Tax consolidation and the structure of corporate groups found in the catalog.

Tax consolidation and the structure of corporate groups

Kazuki Onji

Tax consolidation and the structure of corporate groups

evidence from the Japanese tax reform 2002

by Kazuki Onji

  • 64 Want to read
  • 38 Currently reading

Published by Australia-Japan Research Centre in Canberra .
Written in English

    Subjects:
  • Corporations,
  • Taxation,
  • Fiscal policy

  • Edition Notes

    Includes bibliographical references.

    StatementKazuki Onji
    SeriesAsia Pacific economic paper -- no. 394
    ContributionsAustralia-Japan Research Centre, Crawford School of Economics and Government, ANU College of Asia and the Pacific
    Classifications
    LC ClassificationsHJ2971 .O65 2011
    The Physical Object
    Pagination[i], 4372 p. :
    Number of Pages4372
    ID Numbers
    Open LibraryOL25289290M
    ISBN 100864133480
    ISBN 109780864133489
    LC Control Number2011507218

    Get this from a library! The taxation of corporate groups under consolidation: an international comparison. [Antony Ting] -- Antony Ting presents the first comprehensive comparative study of the tax consolidation regimes adopted in eight countries. Creating a holding company enables a business to maximize the expenses. The normal corporate tax in any country ranges between 25%. There is a possibility that no tax will be triggered when the capital shares are converted into business shares. As a holding company is like a regular business, they come under auspicious tax laws.

    Commercial groups exist through corporate law. Units in the legal structure of a group are individual companies that share common ownership and control. In a public group, a company is owned by the public through shares sold on a stock market. Business Groups. The Oracle E-Business primary consolidation tool is the Oracle Financial.   Therefore, the parent corporation must remit taxes to the IRS whenever group members generate income sufficient to produce a cash tax liability, regardless of whether the group members pay the parent for their share of tax. When a group receives a cash refund because, for example, it carries back a general business tax credit or a pre net.

    The Taxation of Corporate Groups under Consolidation - by Antony Ting December Please note, due to essential maintenance online transactions will not be possible between and BST, on Tuesday 17th September ( EDT, 17 Sep, ). Corporate tax is imposed in the United States at the federal, most state, and some local levels on the income of entities treated for tax purposes as corporations. Since January 1, , the nominal federal corporate tax rate in the United States of America is a flat 21% due to the passage of the Tax Cuts and Jobs Act of State and local taxes and rules vary by jurisdiction, though many.


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Tax consolidation and the structure of corporate groups by Kazuki Onji Download PDF EPUB FB2

The rise of corporate groups in the last century dictates a shift in the income tax law: instead of treating each company as a separate taxpayer, the tax consolidation regime is increasingly common.

Antony Ting presents the first comprehensive comparative study of eight consolidation regimes in Australia, France, Italy, Japan, the Netherlands Cited by: 2. 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 generally means that the head entity of the group is responsible for all or most of the group's tax obligations.

The rise of corporate groups in the last century dictates a shift in the income tax law: instead of treating each company as a separate taxpayer, the tax consolidation regime is increasingly common. Antony Ting presents the first comprehensive comparat. 1 The rise of corporate groups: a challenge to the tax law 3 The rise of corporate groups 3 Tension between traditional legal principle and commercial reality 5 Tax consolidation: a response to the rise of corporate groups 5 The purpose, analytical approach and content of this book 7.

In business, consolidation or amalgamation is the Tax consolidation and the structure of corporate groups book and acquisition of many smaller companies into a few much larger ones.

In the context of financial accounting, consolidation refers to the aggregation of financial statements of a group company as consolidated financial taxation term of consolidation refers to the treatment of a group of companies and other entities as.

Combined tax reporting is a regime which many countries offer to corporate groups for ease of their own administration and reduction of administrative costs, for corporations. Under the combined tax reporting regimes, groups of companies are, for example, allowed to file one joint tax return on an annual basis.

Or, to apply tax consolidation. Tax consolidation: a response to the rise of corporate groups 5 The purpose, analytical approach and content of this book 7 2 Application of the enterprise doctrine to group taxation: theory 13 The separate entity doctrine 13 Historical development of legal personality of companies 13 Companies as separate taxable.

Tax consolidation for corporate groups - Examples with solutions Author(s): Ken SPENCE, Narelle MCBRIDE, Enzo COIA Materials from this session: insert_drive_file; Tax consolidation for corporate groups - Examples with solutions paper (Currently Viewing) $ non.

Consolidation allows wholly-owned corporate groups to operate as a single entity for income tax purposes. Consolidation aims to reduce compliance costs for business, remove impediments to the most efficient business structures and improve the integrity of the tax system.

This links below provide an overview of the operation of the consolidation. Although Canadian corporate groups may be able to undertake loss consolidation transactions through financing arrangements, reorganizations, and transfers of property on a tax-deferred basis, such consolidation is generally more cumbersome and often requires obtaining tax rulings.

A group of companies, under certain conditions, may apply the tax consolidation regime in Luxembourg. In practice, the tax consolidation regime enables the group to pool or offset the respective taxable profit of each company in the group and to be taxed on the aggregate amount (ie, a group of companies is treated as a single taxpayer).

Losses. Losses sustained by group members after the effective date of consolidation are attributed to the group leader for trade and corporate income tax purposes. Pre-consolidation corporate income tax and trade tax losses are not affected by the consolidation and remain within the group member for use after the tax consolidation is terminated (e.g.

making the following mutually exclusive changes to the H Ltd group structure. B Ltd owns 90% of W Ltd. Rather than H Ltd owning A Ltd, C Ltd and D Ltd, the owner is Mr H, a UK resident individual.

The implications are summarised at the end of this article. TAX PLANNING ISSUES RELATING TO GROUP. The regular business tax rates vary between % and % depending on the tax base (taxable income) and the location of the taxpayer. The special local corporate tax rate is % and is imposed on taxable income multiplied by the standard regular business tax rate.

Size-based business tax consists of two components. Rob is PwC's Head of Mining for the Tax Practice in WA and provides services to a number of mining and mining services clients.

Rob provides advice to a number of multinational and ASX listed clients on M&A transactions, cross-border funding and repatriation, tax consolidation and corporate reorganisations. - Current at 01 November Groups of companies Tax consolidation A “tax capital group” may be formed for corporate income tax purposes.

Taxable income for the group is calculated by combining the incomes and losses of all the companies forming the group. A tax capital group may be formed only by limited liability or joint-stock companies based in Poland and under certain.

Get this from a library. The taxation of corporate groups under consolidation: an international comparison. [Antony Ting] -- "The rise of corporate groups in the last century dictates a shift in the income tax law: instead of treating each company as a separate taxpayer, the tax consolidation regime is increasingly common.

tax management skills and proactive collaboration with all parts of the business in advancing the overall objectives. For many organizations, having a tax department structure that centralizes management and resources can help to achieve these ends.

Centralization. The Consolidation and equity method of accounting guide discusses the consolidation framework and equity method of accounting, providing specific guidance and examples related to various topics, such as: The consolidation framework.

Variable interest entities (VIEs) Voting interest entities (VOEs) Equity method investments. Joint ventures (JVs). The impacts of new IRS regulations governing intercompany debt transactions could potentially stretch beyond corporate tax departments to operational functions and, in some cases, strategic decision-making at certain organizations.

The rules, which are issued under Section of the U.S. Tax Code, increase documentation requirements for intercompany debt transactions and, under.

Here is a list of options developed by Veterinary Study Groups (VSG), from its Consolidation Counterpoint Initiative. VSG is the umbrella organization of Veterinary Management Groups, which are made up of independent clinic owners who support and learn from one another by sharing business best practices.

Tax consolidation does not match financial consolidation • The common parent corporation is the agent of all the members in signing the return, paying the tax and receiving notices and refunds (Reg. Sec. ) • All consolidated corporations are jointly and severally liable to the IRS for the group’s tax.There are legal and tax considerations, advantages and possible disadvantages to creating a group company structure.

Most often, setting up such a structure occurs as a business grows. As a result, there will invariably be complex legal and tax issues to consider and deal with.

Our solicitors are experienced and can help.