Download Anglo-American Corporate Taxation: Tracing the Common Roots by Steven A. Bank PDF

By Steven A. Bank

The united kingdom and the united states have traditionally represented contrary ends of the spectrum of their techniques to taxing company source of revenue. less than the British method, company and shareholder source of revenue taxes were built-in lower than an imputation method, with tax paid on the company point imputed to shareholders via an entire or partial credits opposed to dividends got. below the yank procedure, against this, company and shareholder source of revenue taxes have remained separate less than what's known as a 'classical' approach during which shareholders obtain very little reduction from a moment layer of taxes on dividends. Steven A. financial institution explores the evolution of the company source of revenue tax structures in each one kingdom in the course of the 19th and 20th centuries to appreciate the typical criminal, fiscal, political and cultural forces that produced such divergent techniques and explains why convergence should be most probably sooner or later as every one nation grapples with company taxation in an period of globalization.

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Seligman, The Income Tax, p. 166. John G. Hubbard, “Forty Years of Income Tax,” The National and English Review (1884): 772. 74 There was little change in the integrated approach to taxing corporate and individual income during the second half of the nineteenth century,75 but a proposal was raised for the taxation of charitable corporations, which suggests some nuance in the UK’s attitude toward corporate taxation. 76 It was not until 1863, though, that the idea reemerged and focused on corporations.

The financial situation”, 1019. Cong. Rec. vol. 31, p. 5106 (1898) (statement of Sen. ”). 167 Finally, there was also some disagreement about whether this would aid or exacerbate the shifting incidence problem,168 but in the end the revised bill passed with a minimum of debate. Although Congress opted not to tax corporations in 1898, the sugar and petroleum excise taxes set the stage for a later expansion of the concept. In Spreckels Sugar Refining Company v. McClain,169 the court rejected a constitutional challenge to the use of excise taxes in lieu of an income levy.

133 Coupled with the unrest occasioned by the Panic’s economic dislocation,134 the time was ripe for another attempt at an income tax. 137 129 130 131 132 133 134 135 136 137 See Ratner, Taxation and Democracy in America, pp. 126–7; Jeffrey Kwall, “The Uncertain Case against the Double Taxation of Corporate Income,” North Carolina Law Review 68 (1990): 618, n. 23. See Stanley, Dimensions of Law, p. 54. See Bennett Baack and Edward John Ray, “Special Interests and the Adoption of the Income Tax in the United States,” The Journal of Economic History 45 (1985): 608; Witte, The Politics and Development of the Federal Income Tax, p.

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