Corporate/shareholder income taxation and allocating taxing rights between countries : a comparison of imputation systems

목차 (Table of Contents)

• CONTENTS
• PREFACE = xxii
• BOOK Ⅰ THE THEORY OF CORPORATE／SHAREHOLDER INCOME TAXATION
• CHAPTER ONE : INCOME TAX = 1
• 1. Government and Its Need for Revenue = 2
• 1.1 Role and Function of Government = 2
• 1.2 Funding Government = 3
• 1.3 Government Expenditure = 4
• 2. Principles Underlying the Levy of Taxes = 6
• 2.1 Efficiency = 7
• 2.2 Simplicity = 8
• 2.3 Equity = 10
• Levy of Taxes and Redistribution of Welfare = 10
• Relationship to Which Equity Applies = 11
• Concept of "Equity" = 12
• 2.3.1 Benefits Theory = 13
• 2.3.2 Ability to Pay = 14
• 3. Measuring Ability to Pay = 16
• 3.1 Stages of Wealth = 18
• 3.2 Income as the Measure of Tax Capacity = 20
• SHS Income = 21
• SHS Income and the Production and Destruction of Wealth = 21
• SHS Income and the Realisations Base = 25
• 4. Assessing the Income Tax = 27
• 4.1 Equity of the Income Tax = 27
• 4.2 Efficiency of the Income Tax = 31
• 4.3 Simplicity of the Income Tax = 32
• 5. Summary = 34
• CHAPTER TWO : TAXING CORPORATE INCOME = 39
• 1. Relationship Between Corporations and Their Shareholders = 40
• 1.1 Legal Perspective = 42
• 1.2 Economic Perspective = 43
• 1.3 Political Perspective = 46
• 1.4 Recap = 48
• 2. How Corporate Income May Be Taxed = 49
• 2.1 At the Point Corporate Income is Derived = 50
• 2.1.1 Tax Corporations : Corporation tax = 51
• 2.1.2 Tax Shareholders = 51
• 2.1.3 Tax Both Corporations and Their Shareholders = 53
• 2.2 At the Point Corporate Income is Distributed : Dividend Relief = 54
• Double Taxation = 54
• Dividend Relief = 56
• Corporation and Shareholder Tax Bases = 58
• Preference Income = 59
• 2.2.1 No Relief : Classical System = 60
• 2.2.2 Dividend Relief From Corporation Tax = 61
• 2.2.2.1 Reduce Taxable Income : Dividend Deduction System = 61
• 2.2.2.2 Reduce Tax Rate : Split Rate System = 64
• 2.2.2.3 Reduce Tax : Corporation Tax Credit System = 65
• 2.2.3 Dividend Relief From Shareholder Tax = 66
• 2.2.3.1 Reduce Taxable Income : Dividend Exclusion System = 67
• 2.2.3.2 Reduce Tax Rate : Shareholder Differentiation System = 68
• 2.2.3.3 Reduce Tax : Dividend Tax Credit System = 69
• 3. How Corporate Income Has Been Taxed = 72
• 3.1 Before 1920 = 73
• 3.1.1 The United Kingdom = 74
• 3.1.2 The United States = 79
• 3.1.3 Prussia = 82
• 3.1.4 Other Countries = 84
• 3.1.5 Recap = 88
• 3.2 1920 to 1965 = 88
• The United Kingdom = 89
• The United States = 90
• Germany = 90
• Others = 91
• Recap = 95
• 3.3 From 1965 = 95
• 3.4 Recap = 97
• 4. How Corporate Income Should Be Taxed = 99
• 4.1 At the Point Corporate Income is Derived = 99
• 4.1.1 Equity = 100
• Widely Held Corporations = 100
• Closely Held Corporations = 104
• 4.1.2 Efficiency = 107
• 4.1.3 Simplicity = 110
• 4.2 At the Point Corporate Profits are Distributed = 112
• 4.2.1 Equity = 113
• Incidence of Corporation Tax = 113
• Differentiation of Corporate Income = 115
• Which Method of Dividend Relief = 117
• 4.2.2 Efficiency = 120
• Inducement Towards Retention = 120
• Corporate v Unincorporated Sectors = 122
• Form of Financing and Profit Distribution = 123
• Size of Capital Markets = 126
• 4.2.3 Simplicity = 127
• 5. Summary = 130
• CHAPTER THREE : TYPES OF IMPUTATION SYSTEM = 135
• 1. Recording the Corporate Tax = 137
• 1.1 Recording Corporate Profits with Corporation Tax = 140
• 1.1.1 Itemised Approach = 140
• 1.1.2 Pooling with Fixed Tax Treatment = 144
• 1.1.3 Pooling with Variable Tax Treatment = 149
• 1.2 Recording Corporation Tax = 150
• 1.3 Recording Taxable Income = 153
• 2. Adjusting the Shareholder Credit or Corporate Tax = 154
• 2.1 Variable Dividend Tax Credit／Fixed Shareholder Tax = 156
• 2.2 Fixed Dividend Tax Credit／Variable Shareholder Tax = 158
• 2.3 Dividend Withholding Tax／Corporation Tax Credit = 163
• 3. Allocation of Profits as Retained or Distributed = 169
• 3.1 Mandatory Ordering Rules = 170
• 3.2 Discretionary Ordering Rules = 174
• 4. Extent of Imputation = 175
• 4.1 Type of Corporation Tax Excluded = 176
• 4.1.1 All Corporation Tax = 177
• 4.1.2 According to Corporation Tax Treatment = 178
• 4.1.3 According to Type of Income Derived = 179
• 4.1.4 According to Time Income is Derived = 180
• 4.2 How Much Corporation Tax is Excluded = 181
• 4.3 When Corporation Tax is Excluded = 186
• 5. Summary = 187
• CHAPTER FOUR : BEHAVIOUR OF IMPUTATION SYSTEMS = 191
• 1. Measuring the Shareholder Credit by Corporate Tax = 192
• 1.1 What Should be Imputed to Shareholders = 192
• 1.1.1 Changes of Corporate Tax Rate = 193
• 1.1.1.1 Profits Derived After the Change = 194
• 1.1.1.2 Profits Derived Before the Change = 195
• 1.1.2 Corporate Preferences = 200
• 1.1.2.1 Theoretical Justification for Preferences = 201
• 1.1.2.2 Distribution of Preference Income = 203
• Form of Wash Out = 203
• Non-specific Corporate Preferences = 205
• Temporary Corporate Preferences = 206
• Specific Permanent Corporate Preferences = 208
• 1.2 When Imputation Should Occur = 214
• 1.2.1 Theoretical Considerations = 214
• Philosophy of the Imputation System = 215
• Imputation of Future Corporation Tax = 217
• Super-Stacking = 219
• Corporation Tax Adjustments = 221
• 1.2.2 Recording the Corporate Tax and Ordering Options = 222
• Itemised Approach = 223
• Pooling with Fixed Tax Treatment = 223
• Pooling with Variable Tax Treatment = 224
• Recording Corporation Tax = 225
• Recording Taxable Income = 226
• 2. Taxation of Distributions in the Hands of Shareholders = 226
• 2.1 Individual Shareholders = 227
• 2.1.1 Treatment of Excess Dividend Tax Credits = 229
• 2.1.1.1 Refund = 229
• 2.1.1.2 Carry Forward = 231
• 2.1.1.3 Carry Back = 232
• 2.1.1.4 Use Only in the Year of Realisation = 232
• 2.1.2 Dividend Streaming = 234
• 2.2 Corporate Shareholders = 235
• 2.2.1 Exemption of Intercorporate Dividends = 236
• 2.2.2 Taxation of Intercorporate Dividends = 239
• 2.2.3 Use of Dividend Tax Credits = 241
• 2.2.3.1 Redistribution of Dividend Tax Credits = 241
• 2.2.3.2 Excess Dividend Tax Credits = 243
• 2.3 Preference Entities = 246
• 2.3.1 Status of Preference Entities = 247
• 2.3.2 Treatment Under Imputation Systems = 248
• 2.3.2.1 Taxation of Dividends = 249
• 2.3.2.2 Availability and Use of Dividend Tax Credits = 250
• 3. Taxation of Retention in the Hands of Shareholders = 252
• 3.1 Capitalisation and Liquidation = 253
• 3.1.1 Taxation and Imputation on Capitalisation = 253
• 3.1.2 Imputation on Liquidation = 256
• 3.2 Disposal of Shares = 260
• 3.2.1 Capital Gains as a Realisation of Corporate Profits = 261
• 3.2.2 Capital Gains Are Not a Realisation of Corporate Profits = 264
• 4. Summary
• BOOK Ⅱ THE THEORY OF ALLOCATING INCOME TAXING RIGHTS BETWEEN COUNTRIES
• CHAPTER FIVE : ALLOCATION OF INCOME TAXING RIGHTS BETWEEN COUNTRIES = 275
• 1. Income Tax in an Open Community = 276
• 1.1 Economic Allegiance = 276
• 1.2 Allocation Issues of Income Tax = 278
• 1.2.1 Allocation of Source = 278
• 1.2.2 Allocation of Residence = 279
• 1.2.3 Allocation Between Source and Residence = 280
• 2. International Order = 281
• 2.1 How Income Taxing Rights May Be Allocated = 281
• 2.1.1 Methods of Relieving International Double Taxation = 282
• 2.1.2 Intergovernmental Relationship = 284
• 2.2 Development of the International Order = 286
• 2.2.1 Before the League of Nations = 286
• 2.2.1.1 Early United Kingdom and United States Income Taxes = 287
• 2.2.1.2 Developments in Europe Before the First World War = 288
• 2.2.1.3 Developments Throughout the British Empire and the United States at the Time of the First World War = 293
• 2.2.1.4 Developments in Europe Immediately after the First World War = 297
• 2.2.2 Model Tax Treagy Era : League of Nations and the 0EEC／0ECD = 300
• 2.2.2.1 Committee of Four to the 1927／28 Draft Conventions = 300
• 2.2.2.2 1927／28 Draft Conventions to the Mexico／London Models = 304
• 2.2.2.3 Mexico／London Models to the 0EEC／0ECD Models = 306
• 2.2.2.4 OEEC／OECD Models = 308
• 2.3 Principles Governing the Allocation of Corporate Income Taxing Rights = 312
• 2.3.1 Intergovernmental Relationship = 313
• 2.3.2 Source Country／Nonresident Taxpayer Relationship = 315
• 2.3.3 Residence Country／Taxpayer with Foreign Source Income Relationship = 318
• 3. Summary = 320
• CHAPTER SIX : INTERNATIONAL BEHAVIOUR OF IMPUTATION SYSTEMS = 325
• 1. Foreign Source Income of Resident Corporations Distributed to Resident Shareholders = 328
• 1.1 Foreign Tax Relief Not Passed to Shareholders = 329
• 1.1.1 No Foreign Tax ReliefAgainst Corporation Tax = 329
• 1.1.1.1 Behaviour of Imputation Systems = 329
• 1.1.1.2 Intergovernmental Relationship = 330
• 1.1.1.3 Taxpayer／Imputation Country Relationship = 331
• 1.1.2 Wash Out Foreign Tax Relief on Distribution = 333
• 1.1.2.1 Behaviour of Imputation Systems = 333
• 1.1.2.2 Intergovernmental Relationship = 336
• 1.1.2.3 Taxpayer／Imputation Country Relationship = 337
• 1.2 Foreign Tax Treated as Domestic Corporation Tax = 338
• 1.2.1 Behaviour of Imputation Systems = 338
• 1.2.2 Intergovernmental Relationship = 341
• 1.2.3 Taxpayer／Imputation Country Relationship = 342
• 1.3 Pass Through of Corporate Foreign Tax Relief = 344
• 1.3.1 Behaviour of Imputation Systems = 344
• 1.3.2 Intergovernmental Relationship = 347
• 1.3.3 Taxpayer／Imputation Country Relationship = 348
• 2. Domestic Source Income of Resident Corporations Distributed to Nonresident Shareholders = 349
• 2.1 Deny Dividend Tax Credits and Nonresident Shareholder Taxation = 352
• 2.1.1 Behaviour of Imputation Systems = 352
• Treatment in Residence Country = 355
• 2.1.2 Intergovernmental Relationship = 356
• 2.1.3 Nonresident Shareholder／Imputation Country Relationship = 357
• 2.2 Deny Dividend Tax Credits and No Nonresident Shareholder Taxation = 359
• 2.2.1 Behaviour of Imputation Systems = 359
• Treatment in Residence Country = 361
• 2.2.2 Intergovernmental Relationship = 365
• 2.2.3 Nonresident Shareholder／Imputation Country Relationship = 366
• 2.3 Grant Dividend Tax Credits and Nonresident Shareholder Taxation = 366
• 2.3.1 Behaviour of Imputation Systems = 366
• Double Tax Treaty Practice = 368
• Treatment in Residence Country = 376
• 2.3.2 Intergovernmental Relationship = 379
• 2.3.3 Nonresident Shareholder／Imputation Country Relationship = 381
• 3. Foreign Source Income of Resident Corporations Distributed to Nonresident Shareholders = 381
• 3.1 Corporate Tax and Nonresident Shareholder Tax = 384
• 3.2 No Corporate Tax but Nonresident Shareholder Tax = 387
• 3.3 Corporate Tax but No Nonresident Shareholder Tax = 389
• 3.4 No Corporate Tax or Nonresident Shareholder Tax = 393
• 4. Taxation of Income Involving Nonresident Corporations = 397
• 4.1 Domestic Source Income Derived by Nonresident Corporations = 398
• 4.1.1 Behaviour of Imputation Countries = 398
• 4.1.2 Intergovernmental Relationship = 403
• 4.1.3 Nonresident Taxpayer／Imputation Country Relationship = 403
• 4.2 Distributions by Nonresident Corporations to Residents = 405
• 4.2.1 Behaviour of Imputation Countries = 405
• 4.2.2 Intergovernmental Relationship = 412
• 4.2.3 Taxpayer／Imputation Country Relationship = 412
• 4.3 Domestic Source Income Derived Through Nonresident Corporations by Residents = 414
• 4.3.1 Behaviour of Imputation Countries = 414
• 4.3.2 Intelgovernmental Relationship = 416
• 4.3.3 Taxpayer／Imputation Country Relationship = 417
• 5. Summary = 418
• Table 1. Foreign Source Income of Resident Corporations Distributed to Resident Shareholders = 420
• Table 2. Domestic Source Income of Resident Corporations Distributed to Nonresident Shareholders = 424
• Table 3. Domestic Source Income of Resident Corporations Distributed to Shareholders Resident in Other Imputation Countries = 425
• Table 4. Foreign Source Income of Resident Corporations Distributed to Nonresident Shareholders = 427
• Table 5. Comparison of the Treatment of Remittances of Subsidiaries and Permanent Establishments of Nonresident Corporations = 429
• Table 6. Comparison of the Treatment of Intercorporate Distributions of Foreign Source Income Between Resident Corporations with Distributions by Nonresident Corporations to Resident Direct Shareholders = 430
• Table 7. Comparison of the Treatment of Distributions of Foreign Source Income by Resident Corporations to Resident Individuals with Distributions by Nonresident Corporations to Resident Individuals = 431
• Appendix 1. Domestic Source Profits of Resident Corporations Distributed to Nonresident Shareholders : The Interaction of Imputation Systems = 435
• CHAPTER SEVEN : ASSESSING THE INTERNATIONAL ORDER = 443
• 1. Theoretical Limits on Jurisdiction to Levy Income Tax : Symmetry of the Income Tax = 444
• 1.1 Relationship Between Government Services and Transnational Income = 446
• 1.2 Composite Tax Principle = 447
• 2. Assessing the International Order : Applying the Composite Tax Principle = 450
• 2.1 Source Income Tax = 452
• 2.1.1 Applying the Composite Tax Principle = 452
• Example = 459
• 2.1.2 Assessing the International Order = 459
• 2.2 Residence Income Tax = 460
• 2.2.1 Applying the Composite Tax Principle = 460
• Example = 468
• 2.2.2 Assessing the International Order = 470
• 2.3 Intergovernmental Relationship = 477
• 2.3.1 Applying the Composite Tax Principle = 477
• 2.3.2 Assessing the International Order = 482
• 3. Summary = 484
• Appendix 1. Compromise of the Composite Income Tax Approach with Capital Export, Capital Import and National Neutrality = 493
• Graph A. Split of Tax Take Between Source Countries and Country A : Source Portion of 25% and Average Residence Portion of 5.5 % = 494
• Graph B. Split of Tax Take Between Source Countries and Country A : Source Income Tax of 25 % and Income Tax Rate of 40% = 497
• Graph C. Split of Tax Take Between Source Countries and Country A : Source Income Tax of 25 % and Income Tax Rate of 20% = 498
• Graph D. Split of Tax Take Between Source Countries and Country A : Source Income Tax of 25% and Exempt Taxpayers = 499
• CHAPTER EIGHT : HOW IMPUTATION SYSTEMS SHOULD BEHAVE INTERNATIONALLY = 501
• 1. Imputation Systems in a New International Order = 502
• 1.1 Philosophy of Imputation, Flow Through and the Composite Income Tax = 502
• 1.1.1 Foreign Source Income of Resident Corporations Distributed to Resident Shareholders = 504
• 1.1.2 Domestic Source Income of Resident Corporations Distributed to Nonresident Shareholders = 506
• 1.1.3 Foreign Source Income of Resident Corporations Distributed to Nonresident Shareholders = 507
• Example = 508
• 1.1.4 Taxation of Income Involving Nonresident Corporations = 509
• 1.1.4.1 Domestic Source Income Derived by Nonresident Corporations = 509
• 1.1.4.2 Distributions by Nonresident Corporations to Residents = 510
• 1.1.4.3 Domestic Source Income Derived Through Nonresident Corporations by Residents = 510
• 1.2 Imputation Systems in a Broader Theoretical Setting = 510
• 1.2.1 Capitalisation and Liquidation = 511
• 1.2.2 Disposal of Shares = 511
• Example = 514
• 1.2.3 Other Corporate Tax Systems = 518
• Source Classical Corporation Tax = 521
• Residence Classical Corporation Tax = 523
• Partial Integration Systems = 524
• Example = 525
• 1.2.4 Interest Paid by Corporations = 531
• Example = 533
• 1.2.5 Economic Rents = 534
• 2. Implementation Issues = 537
• 2.1 Source Income Tax = 537
• 2.2 Residence Income Tax = 544
• 2.3 Intergovernmental Relationship = 547
• 2.3.1 Unilateral Adoption = 547
• 2.3.2 Adoption Through Bilateral Treaties = 549
• 2.3.3 Adoption Through a Multilateral Treaty = 551
• 3. Summary = 553
• 4. Conclusion = 559
• BOOK Ⅲ THE ANNEXES
• ANNEX 1 : AUSTRALIAN IMPUTATION SYSTEM = 561
• 1. Introduction = 561
• 2. Corporation Tax = 562
• 2.1 Domestic Source Income = 563
• 2.2 Foreign Source Income = 563
• 3. Measuring the Shareholder Credit by Corporate Tax = 566
• 3.1 Recording the Corporate Tax = 566
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 567
• 3.3 Allocation of Profits as Retained or Distributed = 572
• 4. Shareholder Taxation = 573
• 4.1 Distributions = 573
• 4.1.1 Resident Shareholders = 573
• 4.1.1.1 Individual Shareholders = 573
• 4.1.1.2 Corporate Shareholders = 574
• 4.1.1.3 Preference Entities = 575
• 4.1.2 Nonresident Shareholders = 575
• 4.2 Retained Corporate Profits = 576
• 4.2.1 Capitalisation of Profits = 576
• 4.2.2 Disposal of Shares = 577
• ANNEX 2 : FINNISH IMPUTATION SYSTEM = 579
• 1. Introduction = 579
• 2. Corporation Tax = 581
• 2.1 Domestic Source Income = 582
• 2.2 Foreign Source Income = 582
• 3. Measuring the Shareholder Credit by Corporate Tax = 584
• 3.1 Recording the Corporate Tax = 584
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 585
• 3.3 Allocation of Profits as Retained or Distributed = 588
• 4. Shareholder Taxation = 589
• 4.1 Distributions = 589
• 4.1.1 Resident Shareholders = 589
• 4.1.1.1 Individual Shareholders = 590
• 4.1.1.2 Corporate Shareholders = 591
• 4.1.1.3 Preference Entities = 591
• 4.1.2 Nonresident Shareholders = 592
• 4.2 Retained Corporate Profits = 593
• 4.2.1 Capitalisation of Profits = 593
• 4.2.2 Disposal of Shares = 594
• ANNEX 3 : FRENCH IMPUTATION SYSTEM = 595
• 1. Introduction = 595
• 2. Corporation Tax = 596
• 2.1 Domestic Source Income = 597
• 2.2 Foreign Source Income = 597
• 3. Measuring the Shareholder Credit by Corporate Tax = 599
• 3.1 Recording the Corporate Tax = 599
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 600
• 3.3 Allocation of Profits as Retained or Distributed = 605
• 4. Shareholder Taxation = 606
• 4.1 Distributions = 606
• 4.1.1 Resident Shareholders = 606
• 4.1.1.1 Individual Shareholders = 607
• 4.1.1.2 Corporate Shareholders = 607
• 4.1.1.3 Preference Entities = 608
• 4.1.2 Nonresident Shareholders = 609
• 4.2 Retained Corporate Profits = 610
• 4.2.1 Capitalisation of Profits = 611
• 4.2.2 Disposal of Shares = 611
• ANNEX 4 : GERMAN IMPUTATION SYSTEM = 613
• 1. Introduction = 613
• 2. Corporation Tax = 614
• 2.1 Domestic Source Income = 615
• 2.2 Foreign Source Income = 616
• 3. Measuring the Shareholder Credit by Corporate Tax = 617
• 3.1 Recording the Corporate Tax = 618
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 620
• 3.3 Allocation of Profits as Retained or Distributed = 624
• 4. Shareholder Taxation = 625
• 4.1 Distributions = 625
• 4.1.1 Resident Shareholders = 626
• 4.1.1.1 Individual Shareholders = 626
• 4.1.1.2 Corporate Shareholders = 627
• 4.1.1.3 Preference Entities = 628
• 4.1.2 Nonresident Shareholders = 628
• 4.2 Retained Corporate Profits = 630
• 4.2.1 Capitalisation of Profits = 630
• 4.2.2 Disposal of Shares = 631
• ANNEX 5 : IRISH IMPUTATION SYSTEM = 633
• 1. Introduction = 633
• 2. Corporation Tax = 634
• 2.1 Domestic Source Income = 635
• 2.2 Foreign Source Income = 637
• 3. Measuring the Shareholder Credit by Corporate Tax = 637
• 3.1 Recording the Corporate Tax = 638
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 639
• 3.3 Allocation of Profits as Retained or Distributed = 644
• 4. Shareholder Taxation = 645
• 4.1 Distributions = 645
• 4.1.1 Resident Shareholders = 646
• 4.1.1.1 Individual Shareholders = 646
• 4.1.1.2 Corporate Shareholders = 647
• 4.1.1.3 Preference Entities = 648
• 4.1.2 Nonresident Shareholders = 649
• 4.2 Retained Corporate Profits = 649
• 4.2.1 Capitalisation of Profits = 650
• 4.2.2 Disposal of Shares = 650
• ANNEX 6 : ITALIAN IMPUTATION SYSTEM = 651
• 1. Introduction = 651
• 2. Corporation Tax = 652
• 2.1 Domestic Source Income = 653
• 2.2 Foreign Source Income = 654
• 3. Measuring the Shareholder Credit by Corporate Tax = 655
• 3.1 Recording the Corporate Tax = 655
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 658
• 3.3 Allocation of Profits as Retained or Distributed = 661
• 4. Shareholder Taxation = 662
• 4.1 Distributions = 662
• 4.1.1 Resident Shareholders = 662
• 4.1.1.1 Individual Shareholders = 663
• 4.1.1.2 Corporate Shareholders = 664
• 4.1.1.3 Preference Entities = 664
• 4.1.2 Nonresident Shareholders = 665
• 4.2 Retained Corporate Profits = 667
• 4.2.1 Capitalisation of Profits = 667
• 4.2.2 Disposal of Shares = 667
• ANNEX 7 : MALAYSIAN IMPUTATION SYSTEM = 669
• 1. Introduction = 669
• 2. Corporation Tax = 670
• 2.1 Domestic Source Income = 671
• 2.2 Foreign Source Income = 672
• 3. Measuring the Shareholder Credit by Corporate Tax = 673
• 3.1 Recording the Corporate Tax = 673
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 675
• 3.3 Allocation of Profits as Retained or Distributed = 677
• 4. Shareholder Taxation = 679
• 4.1 Distributions = 679
• 4.1.1 Resident Shareholders = 679
• 4.1.1.1 Individual Shareholders = 679
• 4.1.1.2 Corporate Shareholders = 680
• 4.1.1.3 Preference Entities = 681
• 4.1.2 Nonresident Shareholders = 681
• 4.2 Retained Corporate Profits = 682
• 4.2.1 Capitalisation of Profits = 682
• 4.2.2 Disiposal of Shares = 683
• ANNEX 8 : MEXICAN IMPUTATION SYSTEM = 685
• 1. Introduction = 685
• 2. Corporation Tax = 686
• 2.1 Domestic Source Income = 687
• 2.2 Foreign Source Income = 688
• 3. Measuring the Shareholder Credit by Corporate Tax = 689
• 3.1 Recording the Corporate Tax = 689
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 690
• 3.3 Allocation of Profits as Retained or Distributed = 694
• 4. Shareholder Taxation = 694
• 4.1 Distributions = 694
• 4.1.1 Resident Shareholders = 695
• 4.1.1.1 Individual Shareholders = 695
• 4.1.1.2 Corporate Shareholders = 696
• 4.1.1.3 Preference Entities = 697
• 4.1.2 Nonresident Shareholders = 697
• 4.2 Retained Corporate Profits = 697
• 4.2.1 Capitalisation of Profits = 698
• 4.2.2 Disposal of Shares = 699
• ANNEX 9 : NEW ZEALAND IMPUTATION SYSTEM = 701
• 1. Introduction = 701
• 2. Corporation Tax = 702
• 2.1 Domestic Source Income = 703
• 2.2 Foreign Source Income = 703
• 3. Measuring the Shareholder Credit by Corporate Tax = 706
• 3.1 Recording the Corporate Tax = 706
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 707
• 3.3 Allocation of Profits as Retained or Distributed = 712
• 4. Shareholder Taxation = 712
• 4.1 Distributions = 712
• 4.1.1 Resident Shareholders = 713
• 4.1.1.1 Individual Shareholders = 714
• 4.1.1.2 Corporate Shareholders = 714
• 4.1.1.3 Preference Entities = 715
• 4.1.2 Nonresident Shareholders = 715
• 4.2 Retained Corporate Profits = 717
• 4.2.1 Capitalisation of Profits = 718
• 4.2.2 Disiposal of Shares = 718
• ANNEX 10 : NORWEGIAN IMPUTATION SYSTEM = 719
• 1. Introduction = 719
• 2. Corporation Tax = 721
• 2.1 Domestic Source Income = 722
• 2.2 Foreign Source Income = 722
• 3. Measuring the Shareholder Credit by Corporate Tax = 723
• 3.1 Recording the Corporate Tax = 723
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 724
• 3.3 Allocation of Profits as Retained or Distributed = 726
• 4. Shareholder Taxation = 727
• 4.1 Distributions = 727
• 4.1.1 Resident Shareholders = 727
• 4.1.1.1 Individual Shareholders = 728
• 4.1.1.2 Corporate Shareholders = 729
• 4.1.1.3 Preference Entities = 729
• 4.1.2 Nonresident Shareholders = 729
• 4.2 Retained Corporate Profits = 730
• 4.2.1 Capitalisation of Profits = 731
• 4.2.2 Disposal of Share = 731
• ANNEX 11 : SINGAPORE IMPUTATION SYSTEM = 733
• 1. Introduction = 733
• 2. Corporation Tax = 734
• 2.1 Domestic Source Income = 735
• 2.2 Foreign Source Income = 736
• 3. Measuring the Shareholder Credit by Corporate Tax = 737
• 3.1 Recording the Corporate Tax = 737
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 740
• 3.3 Allocation of Profits as Retained or Distributed = 743
• 4. Shareholder Taxation = 744
• 4.1 Disiributions = 744
• 4.1.1 Resident Shareholders = 744
• 4.1.1.1 Individual Shareholders = 745
• 4.1.1.2 Corporate Shareholders = 747
• 4.1.1.3 Preference Entities = 748
• 4.1.2 Nonresident Shareholders = 748
• 4.2 Retained Corporate Profits = 749
• 4.2.1 Capitalisation of Profits = 749
• 4.2.2 Disposal of Shares = 749
• ANNEX 12 : SRI LANKAN IMPUTATION SYSTEM = 751
• 1. Introduction = 751
• 2. Corporation Tax = 752
• 2.1 Domestic Source Income = 753
• 2.2 Foreign Source Income = 753
• 3. Measuring the Shareholder Credit by Corporate Tax = 754
• 3.1 Recording the Corporate Tax = 755
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 756
• 3.3 Allocation of Profits as Retained or Distributed = 761
• 4. Shareholder Taxation = 763
• 4.1 Distributions = 763
• 4.1.1 Resident Shareholders = 763
• 4.1.1.1 Individual Shareholders = 763
• 4.1.1.2 Corporate Shareholders = 765
• 4.1.1.3 Preference Entities = 766
• 4.1.2 Nonresident Shareholders = 766
• 4.2 Retained Corporate Profits = 767
• 4.2.1 Capitalisation of Profits = 767
• 4.2.2 Disposal of Shares = 768
• ANNEX 13 : UNITED KINGDOM IMPUTATION SYSTEM = 769
• 1. Introduction = 769
• 2. Corporation Tax = 770
• 2.1 Domestic Source Income = 772
• 2.2 Foreign Source Income = 772
• 3. Measuring the Shareholder Credit by Corporate Tax = 774
• 3.1 Recording the Corporate Tax = 774
• 3.2 Adjusting the Shareholder Credit or Corporate Tax = 776
• 3.3 Allocation of Profits as Retained or Distributed = 782
• 4. Shareholder Taxation = 784
• 4.1 Distributions = 784
• 4.1.1 Resident Shareholders = 784
• 4.1.1.1 Individual Shareholders = 785
• 4.1.1.2 Corporate Shareholders = 786
• 4.1.1.3 Preference Entities = 787
• 4.1.2 Nonresident Shareholders = 787
• 4.2 Retained Corporate Profits = 788
• 4.2.1 Capitalisation of Profits = 788
• 4.2.2 Disposal of Shares = 788
• GLOSSARY OF TERMS = 791
• TABLE OF ABBREVIATIONS = 801
• TABLE OF CASES = 803
• Books Ⅰ & Ⅱ = 803
• Book Ⅲ = 803
• TABLE OF DOUBLE TAX TREATIES = 805
• Books Ⅰ & Ⅱ = 805
• Book Ⅲ = 808
• TABLE OF STATUTES = 811
• Books Ⅰ & Ⅱ = 811
• Book Ⅲ = 818
• BIBLIOGRAPHY = 843
• Books Ⅰ & Ⅱ = 843
• Book Ⅲ = 864
• INDEX TO BOOKS Ⅰ & Ⅱ = 877