Corporate Taxation in the Netherlands Antilles


Book Description

Corporate income taxation in the Netherlands Antilles is embodied in a law of a total of 57 articles, i.e. Articles" 1 to 54 and Articles 8A, 9A and 14A. The law is divided into nine chapters. Chapter I (Articles 1 to 16) contains the substantive portion of the law and Chapters II to IX are the procedural articles, the penal sanctions, transistory and effectivity provisions. Articles 8A, 9A, 14 and 14A are the Articles which substantially regulate the taxation of off-shore or non-resident companies. It should be noted however, that all the other articles of the law together with additional legislation, e.g. Guaranty Law of 1969, (exept when specifically excluded) are likewise applicable to off-shore com panies. Thus, rules on allowable and allocable deductions, loss carry forward, assessment and collection are identical for both off-shore and on-shore companies. It is a tribute to the legislators who drafted and enacted the present law and the officials who execute it that two totally divergent taxation regimes work in acceptable harmony. History and Background Prior to the introduction of the law on corporate income taxation in 1940, there existed one law on personal income and on profits of entities, regulated in the Income Tax law of 1906.







Kingdom of the Netherlands—Sint Maarten: Technical Assistance Report—Sustainable Tax Reforms


Book Description

Sint Maarten’s economy has been hit hard over the last 4 years. In 2017, two major hurricanes struck the island causing significant damage. While reconstruction was largely financed by insurance proceeds and grants from The Netherlands, economic recovery from the hurricane damage was slow and in early 2020 the coronavirus pandemic shut down most of Sint Maarten’s tourism sector. As a result, fiscal revenue declined by 15 percent since 2016; payroll tax revenue declined by only 4.5 percent, whereas the turnover tax revenue declined by 23 percent. Since April 2020, The Netherlands has provided immediate financial support to cushion the economic shock of the pandemic. In December 2020, Sint Maarten concluded an agreement with The Netherlands to receive more substantial financial support for recovery and ensuring long-term fiscal sustainability. In return, the authorities committed to make structural changes to their tax system, making it more growth-friendly and equitable, while optimizing and ensuring its revenue mobilization capacity.







Taxation of Foreign Investment in the United States


Book Description




Internal Revenue Bulletin


Book Description

A consolidation of all items of a permanent nature published in the weekly Internal revenue bulletin, ISSN 0020-5761, as well as a cumulative list of announcements relating to decisions of the Tax Court.




Federal Taxation of Corporations and Corporate Transactions


Book Description

This first edition of Federal Taxation of Corporations and Corporate Transactions provides a comprehensive examination of tax principles with a unique practice-oriented approach to help students become practice ready with skills that they have developed in a setting that reflects practice in the real world. The casebook introduces students not only to transactional tax practice and the federal tax penalty regime, but also to the rules of professional ethics and the specific rules that govern professionals who practice tax law. It features an array of Deal Downloads that breathe life into complex material, presenting high-profile transactions involving Amazon, Apple, Ford and others. This first edition will have a separately sold Client File supplement, which provides memoranda that require students to analyze the Deal Download transactions and to employ them as precedents to structure acquisitions, investments, and distributions for a hypothetical client. Key Benefits: Client files that are designed to help students learn the law in a practice-like setting. Extensive commentary about tax principles and cites to statutes, cases, regulations, and rulings that the students must study to fully learn the material. Chapter 9, where students will learn about the transaction that heralded the return of Steve Jobs to Apple in the 1990s and paved the way for the company’s subsequent dominant run. An examination of issues posed by classic cases, by focusing on the language of the underlying deal documents, and by learning how to solve clients’ problems before they are set in stone.










Studies in the History of Tax Law, Volume 9


Book Description

These are the papers from the ninth Cambridge Tax Law History Conference, held in July 2018. In the usual manner, these papers have been selected from an oversupply of proposals for their interest and relevance, and scrutinised and edited to the highest standard for inclusion in this prestigious series. The papers fall within five basic themes. Four papers focus on tax theory: Bentham; social contract and tax governance; Schumpeter's 'thunder of history'; and the resurgence of the benefits theory. Three involve the history of UK specific interpretational issues: management expenses; anti-avoidance jurisprudence; and identification of professionals. A further three concern specific forms of UK tax on road travel, land and capital gains. One paper considers the formation of HMRC and another explains aspects of nineteenth-century taxation by reference to Jane Austen characters. Four consider aspects of international taxation: development of EU corporate tax policy; history of Dutch tax planning; the important 1942 Canada–US tax treaty; and the 1928 UN model tax treaties on tax evasion. Also included are papers on the effects of WWI on New Zealand income tax and development of anti-tax avoidance rules in China.