The Resource Tax reporting units and permitted consolidation under host country's income tax law

Tax reporting units and permitted consolidation under host country's income tax law

Label
Tax reporting units and permitted consolidation under host country's income tax law
Title
Tax reporting units and permitted consolidation under host country's income tax law
Creator
Subject
Language
eng
Summary
Host country reports prepared by practitioners in 14 separate jurisdictions. Facts: F is an ownership arrangement formed under the laws of a foreign country (and considered a "corporation" for purposes of that country's income tax laws). F has sent Frank, a Vice President for Operations, to Host Country to promote F's business interests there. In so doing, Frank has formed a number of different ownership arrangements under the business law of State A, a political subdivision of Host Country. Some of these ownership arrangements look like typical business law corporations and partnerships (as those terms are generally understood), and some appear to be unique to State A's business law. Frank has also entered into, on behalf of some of the newly formed ownership arrangements, a number of informal ownership arrangements with unrelated parties. One such arrangement involves joint ownership of a warehouse. Each owner will use part of the warehouse space to store its own merchandise, and non-allocated space will be leased to non-owners from time to time. Questions 1. For purposes of Host Country's income tax law, how does one determine if an ownership arrangement constitutes a tax reporting unit (assuming it has the requisite amount and type of income) and its classification for tax purposes (e.g., corporation or partnership) if it does constitute a tax reporting unit? 2. Does Host Country's income tax law permit consolidation of the income/losses of any tax reporting units and, if so, what are the general rules pertaining to: (a) such consolidation; (b) liability for the consolidated tax (e.g., do the various units have joint and several liability?); (c) how units must contribute to payment of the consolidated tax; and (d) how units must compensate other units for the use of losses, credits, and other tax attributes that serve to reduce tax?
Citation source
In: Tax Management International Forum. - London. - Vol. 26 (2005),
http://library.link/vocab/creatorName
Liebman, H.M.
Language note
English
http://library.link/vocab/subjectName
  • group treatment
  • residence
  • joint and several liability
  • tax liability
Label
Tax reporting units and permitted consolidation under host country's income tax law
Instantiates
Publication
Contents
Belgium p. 3-6 ; Canada p. 7-10 ; Denmark p. 11-16 ; France p. 16-18 ; Germany p. 19-22 ; Hong Kong p. 22-24 ; Ireland p. 24-27 ; Italy p. 27-30 ; Japan p. 31-32 ; Netherlands p. 33-36 ; Spain p. 37-39 ; Switzerland p. 40-41 ; United Kingdom p. 42-46 ; United States p. 47-51
Label
Tax reporting units and permitted consolidation under host country's income tax law
Publication
Contents
Belgium p. 3-6 ; Canada p. 7-10 ; Denmark p. 11-16 ; France p. 16-18 ; Germany p. 19-22 ; Hong Kong p. 22-24 ; Ireland p. 24-27 ; Italy p. 27-30 ; Japan p. 31-32 ; Netherlands p. 33-36 ; Spain p. 37-39 ; Switzerland p. 40-41 ; United Kingdom p. 42-46 ; United States p. 47-51

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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