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This volume presents an introduction to the major topics in the field of federal income taxation, such as income, deductions, and recognition of gains and losses. After discussing central rules and doctrines individually, the author offers an explanation of the interplay among them, carefully describing how they work together to carry out the policy goals of the U.S. tax system.
Tax revenues pay for many public services, including roads, health care, and education. However, it has become a contentious political issue of public debate. In this volume, Stephen Smith explains its history and its main principles; arguing that we'd all benefit from an understanding of the role of taxation in society.
Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.
Global Taxation investigates the global transition to modern taxation from the 18th century to today. Modern taxation refers to the broad-based tax instruments that allowed for the emergence of big government as we know it today, including, most prominently, income taxes and general consumption taxes. The volume draws on a new historical dataset of tax introduction worldwide to map the global spread of modern taxes descriptively and to explore its correlates analytically. It makes four contributions to the literature. First, it corrects a pervasive Western bias in historical political economy and fiscal sociology. Most of this literature focuses heavily on the tax policy of advanced democracies in Europe. The chapters of this volume explore how far Western theories and insights travel to non-Western contexts. Second, the volume mitigates a recency bias in much of the macro-quantitative literature in comparative political economy and public finance. The chapters investigate whether insights travel across time from recent to more distant periods of observation. Third, the volume compensates for the substantive preoccupation of extant research with the personal income tax and the VAT by extending the analysis to other important tax instruments: the corporate income tax, the inheritance tax, non-VAT sales taxes, and social security contributions. Finally, the volume goes beyond the prevalent methodological nationalism in fiscal sociology and comparative political economy. It shows that non-sovereign tax introductions were common in colonial and imperial settings and compares analytically how the logic of these non-sovereign introductions differed from sovereign ones.
Recounts the forgotten early development of the federal income tax in the United States. Topics covered range from marriage, to capital losses, to withholding. This book will be of particular interest to tax academics and professionals, but also to anyone wondering how income tax achieved its current form.
Tax law is political. This book highlights and explains the major themes and methodologies of a group of scholars who challenge the traditional claim that tax law is neutral and unbiased. The contributors to this volume include pioneers in the field of critical tax theory, as well as key thinkers who have sustained and expanded the investigation into why the tax laws are the way they are and what impacts tax laws have on historically disempowered groups. This volume, assembled by two law professors who work in the field, is an accessible introduction to this new and growing body of scholarship. It is a resource not only for scholars and students in the fields of taxation and economics, but also for those who engage with critical race theory, feminist legal theory, queer theory, class-based analysis, and social justice generally. Tax is the one area of law that affects everyone in our society, and this book is crucial to understanding its impact.
Accounting for Income Taxes is the most comprehensive review of AFIT research. It is designed both to introduce new scholars to this field and to encourage active researchers to expand frontiers related to accounting for income taxes. Accounting for Income Taxes includes both a primer about the rules governing AFIT (Sections 3-4) and a review of the scholarly studies in the field (Sections 5-8). The primer uses accessible examples and clear language to express essential AFIT rules and institutional features. Section 3 reviews the basic rules and institutional details governing AFIT. Section 4 discusses ways that researchers, policymakers, and other interested parties can use the tax information in financial statements to better approximate information in the tax return. The second half of the monograph reviews the extant scholarly studies by splitting the research literature into four topics: earnings management, the association between book-tax differences and earnings characteristics, the equity market pricing of information in the tax accounts, and book-tax conformity. Section 5 focuses on the use of the tax accounts to manage earnings through the valuation allowance, the income tax contingency, and permanently reinvested foreign earnings. Section 6 discusses the association between book-tax differences and earnings characteristics, namely earnings growth and earnings persistence. Section 7 explores how tax information is reflected in share prices. Section 8 reviews the increased alignment of accounting for book purposes and tax purposes. The remainder of the paper focuses on topics of general interest in the economics and econometric literatures. Section 9 highlights some issues of general importance including a theoretical framework to interpret and guide empirical AFIT studies, the disaggregated components of book-tax differences and research opportunities as the U.S. moves toward International Financial Reporting Standards (IFRS). Section 10 discusses econometric weaknesses that are common in AFIT research and proposes ways to mitigate their deleterious effects.