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Formulary Apportionment
Formulary apportionment, also known as unitary taxation, is a method of splitting the total pre-tax profit earned (or loss incurred) by a multinational between the tax jurisdictions where it does business. It is an alternative to separate entity accounting, under which a branch or subsidiary within the jurisdiction is accounted for as a separate entity, requiring prices for transactions with other parts of the corporation or group to be assigned according to the arm's length standard commonly used in transfer pricing. In contrast, formulary apportionment attributes a portion of a multinational's total worldwide profit (or loss) to each jurisdiction, based on factors such as the proportion of sales, assets or payroll in that jurisdiction. When applied to a corporate group, formulary apportionment requires combined reporting of the group's results. The parent and all of its subsidiaries are viewed as though they were a single entity (''unitary combination''), and the method is the ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Arm's Length Principle
The arm's length principle (ALP) is the condition or the fact that the parties of a transaction are independent and on an equal footing. Such a transaction is known as an "arm's-length transaction". It is used specifically in contract law to arrange an agreement that will stand up to legal scrutiny, even though the parties may have shared interests (e.g., employer-employee) or are too closely related to be seen as completely independent (e.g., the parties have familial ties). An arm's length relationship is distinguished from a fiduciary relationship, where the parties are not on an equal footing, but rather, power and information asymmetries exist. It is also one of the key elements in international taxation as it allows an adequate allocation of profit taxation rights among countries that conclude double tax conventions, through transfer pricing, among each other. Transfer pricing and the arm's length principle were one of the focal points of the base erosion and profit s ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Internal Revenue Service
The Internal Revenue Service (IRS) is the revenue service for the Federal government of the United States, United States federal government, which is responsible for collecting Taxation in the United States, U.S. federal taxes and administering the Internal Revenue Code, the main body of the federal statutory tax law. It is an agency of the United States Department of the Treasury, Department of the Treasury and led by the Commissioner of Internal Revenue, who is appointed to a five-year term by the President of the United States. The duties of the IRS include providing tax assistance to taxpayers; pursuing and resolving instances of erroneous or fraudulent tax filings; and overseeing various benefits programs, including the Affordable Care Act. The IRS originates from the Commissioner of Internal Revenue, a federal office created in 1862 to assess the nation's first income tax to fund the American Civil War. The temporary measure funded over a fifth of the Union's war expens ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Brookings Institution
The Brookings Institution, often stylized as Brookings, is an American think tank that conducts research and education in the social sciences, primarily in economics (and tax policy), metropolitan policy, governance, foreign policy, global economy, and economic development. Brookings states that its staff "represent diverse points of view" and describes itself as nonpartisan. Media outlets have variously described Brookings as Centrism in the United States, centrist, Modern liberalism in the United States, liberal, and Centre-left politics, center-left. The University of Pennsylvania's ''Global Go To Think Tank Index Report'' has named Brookings "Think Tank of the Year" and "Top Think Tank in the World" every year since 2008. History 20th century Brookings was founded in 1916 as the Institute for Government Research (IGR), with the mission of becoming "the first private organization devoted to analyzing public policy issues at the national level." The organization was founded o ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Consolidation
Tax consolidation, or combined reporting, is a regime adopted in the tax or revenue legislation of a number of countries which treats a group of wholly owned or majority-owned companies and other entities (such as trusts and partnerships) as a single entity for tax purposes. This generally means that the head entity of the group is responsible for all or most of the group's tax obligations (such as paying tax and lodging tax returns). Consolidation is usually an all-or-nothing event: once the decision to consolidate has been made, companies are irrevocably bound. Only by having less than a 100% interest in a subsidiary can that subsidiary be left out of the consolidation. The aim of a tax consolidation regime is to reduce administrative costs for government revenue departments and reduce compliance costs for corporate taxpayers. For companies, consolidating can help understate profits by having losses in one group company reduce profits for another. Assets can be transferred betwe ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Exchange Rate
In finance, an exchange rate is the rate at which one currency will be exchanged for another currency. Currencies are most commonly national currencies, but may be sub-national as in the case of Hong Kong or supra-national as in the case of the euro. The exchange rate is also regarded as the value of one country's currency in relation to another currency. For example, an Interbank lending market, interbank exchange rate of 141 Japanese yen to the United States dollar means that ¥141 will be exchanged for or that will be exchanged for ¥141. In this case it is said that the price of a dollar in relation to yen is ¥141, or equivalently that the price of a yen in relation to dollars is $1/141. Each country determines the exchange rate regime that will apply to its currency. For example, a currency may be floating exchange rate, floating, fixed exchange rate, pegged (fixed), or a hybrid. Governments can impose certain limits and controls on exchange rates. Countries can als ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Accounting
U.S. tax accounting refers to accounting for tax purposes in the United States. Unlike most countries, the United States has a comprehensive set of accounting principles for tax purposes, prescribed by tax law, which are separate and distinct from Generally Accepted Accounting Principles. Basic rules The Internal Revenue Code governs the application of tax accounting.Section 446sets the basic rules for tax accounting. Tax accounting undeemphasizes consistency for a tax accounting method with references to the applied financial accounting to determine the proper method. The taxpayer must choose a tax accounting method using the taxpayer's financial accounting method as a reference point. Types of tax accounting methods Proper accounting methods are described iwhich permits cash, accrual, and other methods approved by the Internal Revenue Service (IRS) including combinations. After choosing a tax accounting method, undesection 446(b)the IRS has wide discretion to re-comput ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Taxable Profit
Taxable income refers to the base upon which an income tax system imposes tax. In other words, the income over which the government imposed tax. Generally, it includes some or all items of income and is reduced by expenses and other deductions. The amounts included as income, expenses, and other deductions vary by country or system. Many systems provide that some types of income are not taxable (sometimes called non-assessable income) and some expenditures not deductible in computing taxable income. Some systems base tax on taxable income of the current period, and some on prior periods. Taxable income may refer to the income of any taxpayer, including individuals and corporations, as well as entities that themselves do not pay tax, such as partnerships, in which case it may be called “net profit”. Most systems require that all income realized (or derived) be included in taxable income. Some systems provide tax exemption for some types of income. Many systems impose tax ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Compliance Costs
Compliance costs are all expenses that a company uses up to adhere to government regulations. Compliance costs incorporate salaries of employees in compliance, time and funds spend on announcing, new system necessitated to meet retention, and so on. Compliance costs happen to be as results of local, national or even international regulation (for instance MiFID II or GDPR applying to countries in European Union). Global firms operating all over the world with varying new regulations in each country tend to face significantly larger compliance costs than those functionating solely in one region. Example – people registered for value added tax (shortly VAT) have to keep records of all tax (input and output) to simplify the completion of returns. They need to employ someone skilled in this domain, which is regarded as compliance cost. Compliance cost mostly includes following: *The cost to assemble and issue reports *Cost of creating and maintenance of the system needed to collect fa ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Double Taxation
Double taxation is the levying of tax by two or more jurisdictions on the same income (in the case of income taxes), asset (in the case of capital taxes), or financial transaction (in the case of sales taxes). Double liability may be mitigated in a number of ways, for example, a jurisdiction may: * exempt foreign-source income from tax, * exempt foreign-source income from tax if tax had been paid on it in another jurisdiction, or above some benchmark to exclude tax haven jurisdictions, or * fully tax the foreign-source income but give a credit for taxes paid on the income in the foreign jurisdiction. Jurisdictions may enter into tax treaties with other countries, which set out rules to avoid double taxation. These treaties often include arrangements for exchange of information to prevent tax evasion such as when a person claims tax exemption in one country on the basis of non-residence in that country, but then does not declare it as foreign income in the other country; o ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
California Franchise Tax Board
The California Franchise Tax Board (FTB) administers and collects state personal income tax and corporate franchise and income tax of California. It is part of the California Government Operations Agency. The board is composed of the California State Controller, the director of the California Department of Finance, and the chair of the California State Board of Equalization. The chief administrative official is the executive officer of the Franchise Tax Board. History In 1879, California adopted its state constitution which among many other programs created the State Board of Equalization and the State Controller, which administered all tax programs.PublicationFranchise Tax Board at a Glance, page 2/ref> In 1929, the state legislature created the office of the Franchise Tax Commissioner to administer California's Bank and Corporation Franchise Tax Act. In 1950, California abolished the office of the Franchise Tax Commissioner and created the Franchise Tax Board as ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Barclays Bank PLC
Barclays PLC (, occasionally ) is a British multinational universal bank, headquartered in London, England. Barclays operates as two divisions, Barclays UK and Barclays International, supported by a service company, Barclays Execution Services. Barclays traces its origins to the goldsmith banking business established in the City of London in 1690. James Barclay became a partner in the business in 1736. In 1896, twelve banks in London and the English provinces, including Goslings Bank, Backhouse's Bank and Gurney, Peckover and Company, united as a joint-stock bank under the name Barclays and Co. Over the following decades, Barclays expanded to become a nationwide bank. In 1967, Barclays deployed the world's first cash dispenser. Barclays has made numerous corporate acquisitions, including of London, Provincial and South Western Bank in 1918, British Linen Bank in 1919, Mercantile Credit in 1975, the Woolwich in 2000 and the North American operations of Lehman Brothers in 2008. ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
