This monograph is principally the work of the late Martin Norr. He completed a draft of the entire monograph but had not yet revised it when he died in late 1972. At that time, the integration of corporate and shareholder taxation was just beginning to become of widespread interest in the United States. With the increasing interest thereafter, the International Tax Program began to revise his manuscript, making as few changes as possible in the original draft. We had the benefit of criticism and analysis from Professor Richard M. Bird of the University of Toronto, now Director of the Institute of Policy Analysis there. In addition, Mr. Mitsuo Sato of the Ministry of Finance in Japan gave freely of his time in carefully suggesting changes throughout the manuscript. The present version of Chapter 3 owes a great deal to his additions and suggestions. Thanks are also due to Professor Hugh J. Ault of Boston College Law School for the Appendix, containing his description of the German integration system that became effective in 1977, which was first published in Law & Policy in International Business. Mr. Norr's interest in the subject of corporate and shareholder taxation developed while he was writing the International Tax Program's World Tax Series volume Taxation in France, published in 1966. The integration of French taxes on corporations and shareholders took place just after that volume was finished, but had been under discussion in France for some time before then.

Silke Rünger aims at investigating the influence of shareholder taxation on corporate ownership with respect to the level of ownership concentration as well as changes in corporate ownership. The empirical investigations show that shareholder taxes are found to influence both, the level of ownership concentration as well as the divestiture choice of single owners and a change in corporate ownership.

The purchase of this ebook edition does not entitle you to receive access to the Connected eBook on CasebookConnect. You will need to purchase a new print book to get access to the full experience including: lifetime access to the online ebook with highlight, annotation, and search capabilities, plus an outline tool and other helpful resources. This well-regarded textbook continues its fundamental approach of clear explanations, pervasive examples, and comprehensive problem sets throughout. Utilizing a problems-based approach, Federal Income Taxation of Corporations and Partnerships, Sixth Edition by Howard E. Abrams and Don Leatherman covers taxation of the three major categories of business entities: Corporations, S Corporations, and Partnerships. New to the Sixth Edition: The text has been updated to reflect the 2017 Tax Cut and Jobs Act. The chapter on taxable acquisitions has been modified to be more complete yet easier to understand. The chapter on tax-free acquisitive reorganizations has been modified to include more problems as well as a section on the substance-over-form doctrine. The Partnership Taxation presentation has been updated to include integration with new bonus depreciation rules, modernization of section 751(b), elimination of technical terminations, and expansion of substantial built-in loss. Professors and students will benefit from: Clarification of the intricacies of the taxation of business enterprises Problems and examples in addition to cases and notes to cover all aspects of the subject Illustrations of typical commercial transactions An emphasis on major themes of policy and practice A book that is flexible enough to be used in two-, three-, or four-credit courses Stand-alone coverage of C corporations, S corporations, and partnerships

This book is designed to be of use to all professionals involved in the asset protection plan, including attorneys, accountants, and financial planners among others. The subjects covered are those that the planner must consider when properly preparing an asset protection plan.

Encapsulating the multitude of challenges faced by the international corporate tax regime, this timely Research Handbook provides an in-depth comparative legal analysis of corporate income tax as it is practiced across the world. With a variety of paths to reform proposed throughout, it will prove an invigorating read for tax scholars working on taxation and tax law as well as for tax practitioners and those in fiscal policy seeking ways to improve, or navigate, the current state of affairs in international corporate tax law.

Presents the recent trends in the taxation of corporate income in OECD countries, discusses the main drivers of corporate income tax reform and evaluates the gains of fundamental corporate tax reform.