The Resource Hybrid entities why not tax pass-through as corporations?

Hybrid entities why not tax pass-through as corporations?

Label
Hybrid entities why not tax pass-through as corporations?
Title
Hybrid entities why not tax pass-through as corporations?
Creator
Subject
Language
eng
Summary
It doesn't make sense to allow certain taxpayers to choose whether they are a corporation or not. The US check-the-box rules, since 1997, have produced a boost to international tax arbitrage. The hybrid entities are the result of the discordances between different jurisdictions, qualifying them at the same time as corporation or pass-through. The misuse of hybrid entities offered a powerful tool for tax minimization on local and foreign earnings. It is not by chance that the financial sector took clear advantages through the special purpose vehicles, structured arrangements, loan and credit transactions and parking of assets for tax purposes. The hybrid entities or reversal hybrid entities meant an incentive for aggressive tax planning. The right solution should be the taxation of pass-through entities as corporations: the partnership income and the attribution income to the partners
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 40 (2012),
http://library.link/vocab/creatorName
Rosembuj, T
Language note
English
http://library.link/vocab/subjectName
  • hybrid entity
  • pass-through entity
  • tax arbitrage
  • check-the-box regulations
  • tax avoidance
  • corporate income tax
  • partnership
  • case law
Label
Hybrid entities why not tax pass-through as corporations?
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Publication
Label
Hybrid entities why not tax pass-through as corporations?
Publication

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