Relevant bibliographies by topics / Qualification for income tax purposes

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  1. Journal articles
  2. Dissertations / Theses
  3. Books
  4. Book chapters
  5. Conference papers
  6. Reports

Academic literature on the topic 'Qualification for income tax purposes'

Author: Grafiati
Published: 13 April 2024

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Journal articles on the topic "Qualification for income tax purposes"

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Khavanova, Inna A. "Islamic (Counterpart) Financing: The Russian Experiment and International Tax Agreements." Banking law 1 (January 18, 2024): 28–38. http://dx.doi.org/10.18572/1812-3945-2024-1-28-38.

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The article analyzes the provisions of the federal law introducing the rules for conducting an experiment to establish special regulation for Partner financing. The peculiarity of Partner financing is that it is consistent with the principles of Islamic finance (Islamic financial model). The author examines the specifics of the qualification of income from Partner financing instruments for the purposes of tax treaties.
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Werlauff, Erik. "Taxation of Foreign Foundations in Light of EU Law." European Company Law 13, Issue 1 (January 1, 2016): 7–13. http://dx.doi.org/10.54648/eucl2016002.

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In Denmark the qualification for tax purposes of a foreign foundation has so far been decided on the basis purely of national tax law. This article argues that it is necessary to consider European law in the testing because it creates a restriction on the freedom of establishment and capital movement if the foundation is not approved as the ‘beneficial owner’ of the income received by the foundation. Such restriction must be able to be justified on the grounds of compelling reasons, suitability and proportionality.
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Shinkareva, O. V., and V. A. Vishnevskiy. "Tax accounting of expenses of medical organizations for professional training of employees." Buhuchet v zdravoohranenii (Accounting in Healthcare), no. 3 (March 18, 2023): 37–46. http://dx.doi.org/10.33920/med-17-2303-04.

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This article considers the specifics of accounting expenses of medical companies for additional professional training of employees for the purposes of calculating corporate income tax. The authors have studied the provisions of labor and tax legislation on the implementation of the employer’s obligation and the employee’s right to master training and professional retraining programs. The conditions under which the employer as a taxpayer can include the amounts spent on the professional training of employees to reduce the tax base in accordance with article 264 of the Tax Code of the Russian Federation have been determined, which, in its turn, is aimed at matching the qualification level of employees to the changing conditions of its professional activity and social environment as well as at getting new or improving the existing professional competences. The results of the study of economic feasibility and expediency of such training are also presented. Practical examples are given.
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Sauer, Christian, Rainer Heurung, and Ariane Bresgen. "Germany’s Statutory Treatment of Special Payments in Transnational Cases." Intertax 42, Issue 10 (October 1, 2014): 644–52. http://dx.doi.org/10.54648/taxi2014057.

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In the field of business taxation, the German and Austrian concepts of co-entrepreneurship (Mitunternehmerschaft) take special positions. Following these concepts, partnership profits are attributed to partner shares and, accordingly, the partners are taxed independently under the transparency or pass-through principle (Transparenzprinzip) based on their respective shares and the special payments they receive from the partnership. Special payments (Sondervergütungen), for instance, interest on a loan granted to the partnership by a partner, are treated as income from commercial business according to domestic law. Therefore, section 50d, paragraph 10, of the Income Tax Act (Einkommensteuergesetz [EStG]) determines that the special payments are treated as a business profit for treaty purposes. As a result, Germany waives the right to tax the partner as a German permanent establishment (PE). In transnational arrangements, the unique German system often results in conflicts of qualification. On this account, our paper points out the consequences resulting from the treatment of special payments. Based on case studies with inbound and outbound investments, we outline the current status of the German treatment of special payments in transnational dealings and summarize future prospects.
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Pandyak, Igor. "System of taxation of hotel enterprises in Ukraine." Visnyk of the Lviv University. Series Geography, no. 54 (November 26, 2020): 142–49. http://dx.doi.org/10.30970/vgg.2020.54.11828.

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The taxation system of hotel enterprises in Ukraine according to their organizational and legal status is analyzed. The influence of the tax system on the organizational and functional characteristics of hotels – staff, specialization, indicators of financial and economic activity, qualification of accountants, financial statements, etc. is revealed. The advantages and disadvantages of the general and simplified tax system in Ukraine are described. Most hotel businesses use a simplified tax system. The connection between the state tax policy in the hotel industry and investment activity is revealed. Taxation is a key point in which the government supports investment-attracting businesses. Support is provided in the form of reduced income tax rates, tax benefits. The state, by not receiving budget revenues, encourages hotel companies to reduce their income tax expenditures to invest more in business and increase profits. It is important, together with the reduction in the tax rate, to use means of influence for the purpose of tax relief. In Ukraine, the tax system does not promote investment in the hotel industry. The mechanism of application of tax privileges in countries known to the tourist specialization is characterized. It has been revealed that the hotel taxation system is one of the key factors of their microeconomic development, financial capacity building, and at the same time an instrument of investment in the hospitality sector of Ukraine. Reducing the profit tax rates of hotel companies from 21% to 18% contributes to improving their financial status, increasing production capacity, and improving service levels. However, such a tool cannot be a guarantee of reinvestment in an enterprise. Targeted tax benefits are considered more effective, for example: significantly reducing or exempting companies by category, type, capacity, location of income tax for a specified period. At the same time, with the reduction of the tax rate, it is necessary to use the means of influence to comply with the subjects of the hotel business with the targeted application of tax benefits. Key words: hotel enterprises, tax system, tax breaks, profit of enterprises, investments, investment climate.
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Tangian, Andranik. "Decent work: indexing European working conditions and imposing workplace tax." Transfer: European Review of Labour and Research 15, no. 3-4 (August 2009): 527–56. http://dx.doi.org/10.1177/10242589090150031801.

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This article indexes working conditions using data from the Fourth European Working Conditions Survey 2005 for three purposes. (1) Benchmarking countries and social groups. This reveals poor qualification and career opportunities, and modest incomes. Atypical workers have less advantageous working conditions than those in permanent full-time jobs. This shows that Europe is still far from creating ‘better jobs’ as advocated in the Lisbon agenda. (2) Analysing the flexicurity concept as proposed by the European Commission. Our study disproves the assertion that European workers are less interested in remaining with the same employer but need more flexibility combined with ‘upward mobility’ and lifelong learning. Moreover, Europe has a shortage of training possibilities and workers demonstrate latent resistance to learning. The basis for the Commission's promotion of flexicurity would thus seem questionable. (3) Proposal of a workplace tax for bad working conditions. As with ‘green taxes’, the workplace tax would encourage employers to improve working conditions. Indexing individual working conditions with reference to a checklist, as developed in the article, could be a prototype for measuring ‘social pollution’ to determine the amount of workplace tax.
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Sentsova (Karaseva), M. V. "The legal qualification of transactions for tax purposes." Russian Journal of Legal Studies 3, no. 3 (September 15, 2016): 111–16. http://dx.doi.org/10.17816/rjls18173.

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In the clause it is underlined that quite often the rights of tax payer are demanded by protection in connection with wrong qualification of the transactions made by the tax payer. The drawbacks of the qualifications take place in activity of tax departments and courts.
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Kulicki, Jacek. "Zasady opodatkowania dochodów i obrotów ze sprzedaży produktów wytwarzanych w gospodarstwach rolnych." Zeszyty Prawnicze Biura Analiz Sejmowych 1, no. 69 (2021): 189–215. http://dx.doi.org/10.31268/zpbas.2021.16.

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The analysis of the applicable regulations leads to the conclusion that the system of taxation of farmers’ income is complex. The author points out different definitions of agricultural activity for the purposes of income tax and value added tax. The legislator makes the classification of agricultural income among individual sources of income for the purposes of personal income tax dependent on whether they are processed or unprocessed products and on the method of their processing. The differences in the treatment of farmers’ revenues for the purposes of income tax overlap with the tax obligations with regard to value added tax and excise tax.
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Tiley, John. "Income Tax—Purposes and Trading Transactions." Cambridge Law Journal 50, no. 3 (November 1991): 416–18. http://dx.doi.org/10.1017/s0008197300016159.

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Van Schalkwyk, Linda, and Rudie Nel. "Non-executive directors: Employees or independent contractors for both income tax and employees’ tax purposes?" Journal of Economic and Financial Sciences 6, no. 2 (July 31, 2013): 401–20. http://dx.doi.org/10.4102/jef.v6i2.267.

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The concept ‘independent contractor’ is one of the more contentious concepts contained in the Fourth Schedule to the Income Tax Act 58 of 1962, as amended. The classification of a person rendering services as either an ‘employee’ or an ‘independent contractor’ is relevant for both income tax and employees’ tax purposes. The objective of this article is to determine whether non-executive directors (both resident and non-resident) are employees or independent contractors for both purposes, respectively. A comprehensive literature review was done in which the meaning of the concepts ‘non-executive director’ and ‘independent contractor’ was discussed in order to gather information needed for the classification. The statutory and common law tests were then applied to determine the classification of non-executive directors as independent contractors. The conclusion reached is that resident non-executive directors could qualify as ‘independent contractors’ for employees’ tax and income tax purposes. Non-resident non-executive directors of companies are ‘employees’ for employees’ tax purposes and ‘independent contractors’ for income tax purposes.
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Dissertations / Theses on the topic "Qualification for income tax purposes"

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Vorster, Jana. "Differentiating between processes of manufacture and other processes within a business for purposes of the Income Tax Act." Pretoria : [s.n.], 2009. http://upetd.up.ac.za/thesis/available/etd-03022009-102421/.

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Van, der Westhuizen Francois Duplessis. "Venture and trade conducted by natural persons for income tax purposes." Pretoria : [s.n.], 2009. http://upetd.up.ac.za/thesis/available/etd-04092009-142658/.

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Moshe, Shekel. "Recognition of income form deposits and advance payments for tax purposes." Thesis, Brunel University, 2007. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.488686.

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This thesis is concerned with the theoretical and computational aspects of generating solutions to problems involving materials with fading memory, known as viscoelastic materials. Viscoelastic materials can be loosely described as those whose current stress configuration depends on their recent past. Viscoelastic constitutive laws for stress typically take the form of a sum of an instantaneous response term and an integral over their past responses. Such laws are called hereditary integral constitutive laws.
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Naidu, Aveshni. "A critical analysis of the deductibility of bad debts for income tax purposes." Thesis, Rhodes University, 2018. http://hdl.handle.net/10962/61712.

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The objective of this thesis was to critically analyse the deductibility of bad debts for income tax purposes. This was achieved by applying a doctrinal research methodology to the data, which consisted of local and international legislation and case law, as well as other relevant writings. In setting out to achieve this primary objective, this thesis addressed certain subsidiary goals. The requirements of section 11 (i) of the South African Income Tax Act that provides for the deduction of bad debts were examined with reference to local case law, together with case law from selected international jurisdictions. To clarify the requirement of section 11 (i) that a debt must have become bad, this thesis set out to ascribe a meaning to the term “bad debt” which is currently not defined in the South African Income Tax Act and to ascertain the principles applicable in determining when a debt will be regarded as having become bad. The research also addressed the timing in relation to the identification of a debt as bad, as well as other commercial considerations. This research concluded that there is a need for further guidance in this area and provided brief recommendations that could provide more certainty in relation to the deductibility of bad debts.
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Fourie, Christine. "A comparative analysis of the meaning of 'mining operations' for income tax purposes." Master's thesis, University of Cape Town, 2017. http://hdl.handle.net/11427/27247.

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The South African ("SA") mining industry played (and continues to play) a pivotal role in the development of the SA economy. It is therefore no surprise that the industry has long been the beneficiary of favourable tax concessions. One of these favourable tax concessions is the 100% capital expenditure allowance. Access to this allowance is dependent on the interpretation of the definition of "mining operations" in section 1(1) of the Income Tax Act, No. 58 of 1962 ("the ITA"). Currently, there is legal uncertainty in SA regarding the meaning of "mining operations". This is so because central to the term "mining operations" is the term "mineral", which is not defined in the ITA, nor does it have an ordinary fixed meaning. SA courts have further not authoritatively dealt with the meaning of "mining operations" despite being presented with the opportunity to do so in recent case law. This legal uncertainty is further fuelled by a recent draft interpretation note issued by the South African Revenue Service ("SARS"), expressing the view that quarrying operations for inter alia clay for brickmaking and limestone for the manufacture of cement, do not constitute "mining operations". Practically, this legal uncertainty may act as a deterrent to mining companies incurring capital expenditure, essentially curbing the development of the SA mining industry. This study seeks to analyse the different meanings attributed by SARS, SA academic writers and SA courts to the definition of "mining operations" (and the related meaning of "mineral") for income tax purposes. The purpose of this analysis is to determine whether the extraction of clay for brickmaking and limestone for the manufacture of cement constitutes "mining operations". Against this background, Australian legislation and case law on the interpretation of the term "mining operations" and "mineral" will be studied in order to draw a comparison between SA and Australia's treatment of "mining operations". This study further interprets the meaning of "mining operations" through the application of the Savignian interpetation model in terms of which it is concluded that useful guidance can be sought by SA from Australian jurisprudence when interpreting the meaning of the term "mining operations" for income tax purposes and that the purposive test applied in Australia should be adopted by SA courts. Based on the application of this guidance, the key finding of this dissertation is that the extraction of clay for brickmaking and limestone for the manufacture of cement should in principle qualify as "mining operations" and that the capital expenditure incurred in this regard should be eligible for the 100% capital expenditure allowance.
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Gousmett, Michael Joseph. "The Charitable Purposes Exemption from Income Tax:Pitt to Pemsel 1798-1891." Thesis, University of Canterbury. Accounting and Information Systems, 2009. http://hdl.handle.net/10092/3448.

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Abstract In the Assessed Taxes Act 1798, and the Duties upon Income Act 1799, William Pitt the Younger provided exemptions from those taxes for charitable institutions. However, the legislation failed to provide a definition of charitable purposes with respect to either Assessed Taxes or Duties upon Income. The problems for charitable institutions began when Addington introduced deduction at source in 1803, thus catching charitable institutions in the tax net by requiring them to claim refunds of Income Tax that had been deducted from their non-voluntary income. To deal with the issues arising from such claims, Pitt created the Special Commissioners in 1805. The Duties upon Income Act 1799 and its successors were only intended as temporary war-time taxes, and Income Tax was eventually repealed in 1816 once peace with France had been achieved. However, Peel reintroduced Income Tax in 1842, based on the earlier Income Tax Acts. Once again, Income Tax was intended only as a short-term fiscal measure, but that was not to be and, during the course of the Nineteenth Century, the Income Tax became a permanent fixture of the legislative calendar. However, the issue of what was understood by the term “charitable purposes” with respect to Income Tax became an issue which, it was suggested in 1863, Parliament should resolve. That was not to be, and it was not until 1891 that Lord Macnaghten, in Commissioners for the Special Purposes of the Income Tax v Pemsel [1891] AC 531 laid down the four principal divisions of charity that continue to dominate charity case law in the Twenty-First Century. Until then, the exemption of charitable institutions from Income Tax had been a contentious issue. Anthony Highmore, a London lawyer who was also very active in a number of London’s charities in the late Eighteenth and early Nineteenth Centuries until his death in 1829, proposed in 1786, that charities should be exempt from all forms of taxation. In 1863 Gladstone unsuccessfully challenged the exemption of charitable institutions from Income Tax, arguing that income other than voluntary donations should be taxed, and that governments should decide which charitable institutions were worthy of direct government funding. However, charity case law continued to influence the decisions of the Special Commissioners until ultimately in 1891 Pemsel resolved the issue in a case which continues to resonate in the Twenty-first Century. The question that this Thesis seeks to answer is, what was the rationale for the charitable purposes exemption from Income Tax that Pitt had provided in his Income Tax Acts? I propose that the rationale was not founded in fiscal policy, or charity case law, but in social policy as influenced by the Evangelicals of late Eighteenth Century London, predominantly William Wilberforce and Hannah More, who were close friends of William Pitt the Younger.
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Stopforth, David Paul. "A history of the anti-avoidance legislation applying to settlements for income tax purposes." Thesis, University of Glasgow, 1988. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.254093.

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Govender, Preshnee. "Does a mineral right constitute 'immovable property' for purposes of the Income Tax Act and double tax treaties?" Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/9170.

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This research paper analyses the income tax impact for international (non-resident) companies that dispose of their shares in mining or oil and gas companies situated in South Africa. Typically, a disposal of shares by a non-resident in a property-rich company in South Africa would attract CGT. In the case of the minerals sector, it is automatically assumed that a mining or oil and gas company is a so-called “land-rich” or “property-rich” company due to the nature of its operations. This paper seeks to test that assumption, ie do shares in a mining or oil gas company whose only asset is a mining or prospecting right or exploration or production right respectively qualify as an ‘interest in immovable property’ as that term is defined in the ITA for CGT purposes? To make this determination, the term ‘immovable property’ as it is used for common –law purposes and the potential misalignment of this definition when compared to the term as it is used in the ITA must be analysed.
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Pickup, Richard Kenneth. "A critical analysis of the deductibility for income tax purposes of dual-purpose expenditure." Thesis, Rhodes University, 2016. http://hdl.handle.net/10962/4155.

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This thesis critically analysed the apportionment of dual-purpose expenditure. In doing so, two categories of dual-expenditure were examined: expenditure that has been incurred for both trade and non-trade purposes, and expenditure that has been incurred to produce both taxable and exempt income. In conducting this analysis, this thesis set out to answer three questions: has the apportionment of dual-purpose expenditure been officially sanctioned in South Africa, when does the need for apportionment arise, and on what basis should a taxpayer apportion expenditure that has been incurred for a dual purpose? A doctrinal methodology was applied to the documentary data which consisted of relevant tax legislation; South African, Australian and English case law; and commentary of experts in the field of tax law. From the analysis performed, it was revealed that the apportionment of dual-purpose expenditure has been officially sanctioned in South Africa. In addition, it was concluded that the applicable legal principles for determining the need for apportionment and for performing the apportionment calculation are clear and well-established. The difficulty which taxpayers, the courts and the South African Revenue Service face, however, is applying these principles in practice. This research therefore concluded that there is a need for further guidance in this complex area of tax law. In addition, this research proposed some recommendations which could provide more certainty and clarity.
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Cloete, Loriaan. "A critical analysis of the distintion between mining and manufacturing for South African income tax purposes." Thesis, Nelson Mandela Metropolitan University, 2010. http://hdl.handle.net/10948/1344.

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"Mining operations" and "mining" are defined in s 1 of the Income Tax Act (ITA). A concept that is of great significance to this definition is the matter of when a mineral is won and the related question of when does the mining process end and the process of manufacture commences. Case law has not established a definitive point that can be used by the mining taxpayer to determine where the mining process ends for income tax purposes. The Supreme Court of Appeal was presented with the perfect opportunity in the Foskor1 case to clearly define the boundaries between these processes. Unfortunately, the court did not seize this opportunity to provide legal certainty. The significance of the distinction lies in the fact that a mining taxpayer is allowed to claim accelerated capital allowances. The objective of these allowances is to provide tax relief to the mining taxpayer taking the immense risk of investing billions of rands in capital expenditure. The capital expenditure incurred will also result in direct foreign investment. This in turn will result in economic growth and job creation. Currently, there is no legal certainty as to which processes will qualify as mining operations for income tax purposes. This may result in mining taxpayers being hesitant to incur capital expenditure as the risk relating to a project would have increased. The accelerated capital allowances may therefore not serve their intended purpose. The gross domestic product (GDP) contribution from gold mining has been decreasing in the last number of years, but this decrease has to a large extent been offset by an increase in the downstream or beneficiated minerals industry. This industry has also been identified by Government as a growth sector. The downstream or beneficiated mineral industry may not be catered for in the current definition of "mining operations" and "mining" and may therefore not qualify for beneficial tax allowances. It is therefore proposed that the term "won" as used in the definition of "mining operations" and "mining" should be defined in s 1 of the ITA as follows: A mineral is "won" when all the requisite and necessary processes, including, amongst other things, refinement, beneficiation, smelting, separation, have been undertaken to the mineral to render it saleable in an open and general market. This extension will provide legal certainty to a mining taxpayer and will ensure that South Africa obtains direct foreign investment and maximum value for its minerals. This will contribute to economic growth for South Africa's developing economy and result in job creation.
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Books on the topic "Qualification for income tax purposes"

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Great Britain. Board of Inland Revenue. Farming: Stock valuation for income tax purposes. [London]: Inland Revenue, 1990.

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Corporate Management Tax Conference. (24th 1987 Toronto, Ont.). Current developments in measuring business income for tax purposes: Corporate Management Tax Conference 1987. [Toronto]: Canadian Tax Foundation, 1987.

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Forsyth, Andrew W. Classification of workers for purposes of federal employment taxes. [S.l.]: A.W. Forsyth, 1995.

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Canada. Applications for certification of cultural property for income tax purposes: Informaton and procedures. Hull, Québec: Canadian Cultural Property Export Review Board, 1996.

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Canada. Applications for certification of cultural property for income tax purposes: Informaton and procedures. Ottawa, Ont: Canadian Cultural Property Export Review Board, 1995.

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An Act to Amend the Internal Revenue Code of 1986 to Repeal the Imposition of 3 Percent Withholding on Certain Payments Made to Vendors by Government Entities, to Modify the Calculation of Modified Adjusted Gross Income for Purposes of Determining Eligibility for Certain Healthcare-Related Programs, and for Other Purposes. Washington, D.C: U.S. G.P.O., 2011.

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Organisation for economic co-operation and development. Global forum on transparency and exchange of information for tax purposes peer reviews: Bahrain 2011. [Paris]: OECD, 2011.

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US GOVERNMENT. An Act to Extend the Tax Benefits Available with Respect to Services Performed in a Combat Zone to Services Performed in the Federal Republic of Yugoslavia (Serbia/Montenegro) and Certain Other Areas, and for Other Purposes. [Washington, D.C: U.S. G.P.O., 1999.

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United States. Internal Revenue Service., ed. Actuarial values.: Tables for computing depreciation adjustment factors : interest rates from 2.2 percent to 22.0 percent : for income tax purposes only. [Washington, D.C.]: Dept. of the Treasury, Internal Revenue Service, 1999.

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United States. Congress. House. Committee on Ways and Means. Subcommittee on Select Revenue Measures. Misclassification of employees and independent contractors for federal income tax purposes: Hearing before the Subcommittee on Select Revenue Measures of the Committee on Ways and Means, House of Representatives, One Hundred Second Congress, second session, July 23, 1992. Washington: U.S. G.P.O., 1992.

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Book chapters on the topic "Qualification for income tax purposes"

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Ligthart, Jenny E., Barbara Maria Sadaba, and Rene van Stralen. "What Determines Information Sharing for Income Tax Purposes: The Swedish Case." In Financial Crimes: Psychological, Technological, and Ethical Issues, 59–82. Cham: Springer International Publishing, 2016. http://dx.doi.org/10.1007/978-3-319-32419-7_3.

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Bizioli, Gianluigi. "Qualification Conflicts and Tax Treaties." In The Oxford Handbook of International Tax Law, 285—C17N28. Oxford University Press, 2023. http://dx.doi.org/10.1093/oxfordhb/9780192897688.013.18.

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Abstract This chapter examines qualification conflicts and tax treaties. Qualification conflicts in tax treaty law raise two different issues. The first involves defining the boundaries of the topic and, in particular, the differences and the overlapping of the contiguous terms and activities of interpretation, classification, and characterization. This issue is common to every legal order and the conflicts are always due to a varying interpretation by two jurisdictions. The second, differently, involves the consequences of these conflicts on international taxation, in particular double taxation or double non-taxation of the same income in the hands of the same taxpayer by two (or more) different jurisdictions. The chapter presents a literature review of the issue, with particular emphasis on the OECD and the UN documents, on the commentaries, and on monographs on the topic. It looks at the critical analysis of the causes as well as the solutions provided, their coherence with the principles of international taxation, and ability to pursue the objectives.
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Tuomala, Matti. "An Optintal Integrated Tax System." In Optimal Income Tax and Redistribution, 160–80. Oxford University PressOxford, 1990. http://dx.doi.org/10.1093/oso/9780198286059.003.0010.

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Abstract So far we have focused our attention on the design of a labour income tax. Other tax and expenditure policies are also often used for the purposes of redistribution. The balance between income taxation and other taxation is undoubtedly one of the oldest issues in taxation policy. In this chapter the interrelation of income tax with other instruments of tax and expenditure policy will be considered in the light of modern optimal tax theory. It is almost conventional wisdom that income taxation is superior as an instrument of redistribution. Commodity taxes, public-sector pricing, and the supply of public goods have been regarded only as a means of allocating resources, not for redistribution. One of the purposes of this chapter is to see how these beliefs hold when income taxation and other instruments are considered in an integrated model.
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Lambooij, Machiel. "Netherlands: Nexus for Purposes of Imposing Corporate Income Tax." In Global E-Business Law & Taxation, 205–26. Oxford University PressNew York, NY, 2009. http://dx.doi.org/10.1093/oso/9780195367218.003.0013.

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Abstract This chapter discusses in general terms, without focusing on any specific jurisdiction, the concept of “nexus” with a taxing jurisdiction required for a person (the e-tailer) resident outside that jurisdiction to be subject to tax on its business profits earned in connection with its e-commerce activities. It then discusses specifics about The Netherlands’ position. The jurisdiction where the customers of the foreign e-tailer are based is hereinafter referred to as the source state. The term nexus refers to the threshold an e-tailer will have to surpass in terms of presence (physical, virtual, or otherwise) in the target jurisdiction in order to become taxable there on its profits. Profit allocation and other tax-base issues, once it has been established that there is sufficient relevant nexus, are not the subject of this article.
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Dyson, Henry. "Inheritance And Gifts Tax." In French Property And Inheritance Law-Principles And Practice, 339–52. Oxford University PressOxford, 2003. http://dx.doi.org/10.1093/oso/9780199254750.003.0039.

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Abstract French inheritance tax (droits de succession) is payable on the death of every person domicilié fiscalement or resident for income tax purposes in France on all his assets wherever situate in the world. In the case of a person who died not resident for tax purposes in France, droits de succession are payable in the case of a beneficiary who is not resident in France only in respect of assets situate in France. If the beneficiary was resident in France at the date of the death of the deceased and had been so resident for at least six out of the preceding ten years, the tax is payable in respect of all assets inherited by that beneficiary whether they are situate in or out of France.
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Teixeira, Glória, and Ana Sofia Carvalho. "As Novas Formas de Tributação." In The Overarching Issues Of The European Space. Sustainable development and territorial preservation in a globalized world, 51–66. Faculdade de Letras da Universidade do Porto, 2022. http://dx.doi.org/10.21747/978-989-9082-57-1/overa3.

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The new forms of taxation appear as a result of new ways of thinking and operation, namely through a mature respect of human rights, elimination of discriminatory features of tax laws and better performance of tax administrations, direct result of new scientific and technologic developments. The new philosophical thinking of the XXI century starts to produce its effects, not only by the introduction of more adequate tax laws but also in the type of work and inspective processes used by tax administrations. Principles of neutrality, non-discrimination and simplicity prevail over the tradicional principles of equity (or income ability and related extreme progressivity application over employee and pension incomes) and residence (actual compass in the delimitation of the tax jurisdictional power of the states). Taxpayers demand tax laws more rational, both at personal and corporate income tax levels, but also at consumption and property tax levels. It is expected, as a result of the new philosophical tendencies that started to guide the XXI century, to end up with less taxes but with more fairer and simple taxes. Indeed, the purposes of the tax system are financial purposes, but also extrafiscal purposes (a fair distribution of income and wealth). Such extra-tax purposes include, inter alia, the implementation of the principles of neutrality and non-discrimination. For example, by verifying that women receive less than the other gender, and the state still manages to benefit from the tax burden of the most expensive products they consume, it is necessary to draw the attention of political leaders to the need for greater protection of women in unemployment and old age. In turn, corporate income tax should be seen not as a mere source of revenue collection, but as an instrument of economic growth, growth that can be enhanced with proposals such as the elimination of “derrama estadual” and the transformation of corporate income tax into a regressive tax, in order to encourage companies to be more profitable and efficient.
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Avi-Yonah, Reuven S. "The Origins of Destination-Based Income Taxation." In VAT in the Digital Era, 274–85. Oxford University PressOxford, 2023. http://dx.doi.org/10.1093/oso/9780198888307.003.0013.

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Abstract Value-added taxes are destination based; that is, tax is imposed on imports and exports are zero-rated (so that the exporter can receive a refund on VAT collected in previous stages of production). Income taxes, on the other hand, are typically origin based; that is, imports are deductible and exports are taxed. However, from the very beginnings of the international tax regime, it was recognized that this treatment of income for tax purposes is unfair to destination countries which contribute to the profit created by the market. The introduction of the permanent establishment (PE) threshold and the arm’s-length standard (ALS) for dividing the income among related taxpayers significantly limited the ability of destination countries to tax cross-border business income. As early as the start of the 1990s, critics were arguing that formulary apportionment including a sales factor was a better alternative for international taxation than PE and the ALS. Pillar One of Base Erosion and Profit Shifting (BEPS) 2.0 (2018) provided a partial solution that discards the PE and ALS limits on 25 per cent of the residual income of the largest multinationals. This solution may be adopted unilaterally even if Pillar One fails.
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Kaminski, Stanley R. "United States: The Allocation and Sourcing of Service Income in E-Commerce for State Income Tax Purposes." In Global E-Business Law & Taxation, 421–34. Oxford University PressNew York, NY, 2009. http://dx.doi.org/10.1093/oso/9780195367218.003.0026.

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Abstract Currently, there are 45 states (and the District of Columbia) in the United States that impose some form of corporate income tax, as well as 4 states that impose a type of gross or adjusted gross revenue/receipts tax. While many of these taxes are similar in kind, there are exclusions, terminology, interpretation, and application differences that impact how these taxes are imposed. As to the taxation of income from the sale of services, differences in the sourcing or allocation of such services also arise depending on the type of service being sold. Nevertheless, income from the sale of services is generally sourced or allocated based on either (1) the location at which the service is performed (commonly cost of performance is used for this analysis); or (2) the location of the benefit of the service to the customer (sometimes customer receipt or billing location is used for this purpose).
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Öz, Semih N. "International Tax Competition and Its Reflections in Turkey." In Handbook of Research on Public Finance in Europe and the MENA Region, 176–200. IGI Global, 2016. http://dx.doi.org/10.4018/978-1-5225-0053-7.ch009.

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International tax competition has been significantly increased since 1980s as a result of liberalized financial and fiscal policies, while this leads sovereign nations faced budgetary deficit problems and public finance related considerations. This paper aims to analyze how Turkish tax system is affected by international tax competition, services submitted by tax havens and facilities used by multinationals. In 2006, a new Corporate Income Tax Law was introduced in Turkey. One of its purposes is to combat against harmful tax competition and therefore it covered defensive measures such as controlled foreign company (CFC), thin capitalization rule and transfer pricing regulation, to prevent companies from leaving their income abroad. This study aims to analyze effects of international tax competition in Turkey whether there are change in tax rates, tax structure, and tax revenue; and how the government respond it, as a beneficiary; or, a loser.
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Smith, Andre L. "Recent Cases of Regressive and Racially Disparate Taxation in the United States." In Tax, Inequality, and Human Rights, 469–86. Oxford University Press, 2019. http://dx.doi.org/10.1093/oso/9780190882228.003.0022.

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This chapter assesses whether there is a national trend in the United States toward disproportionate imposition of regressive taxes on low-income communities of color, reflective of a deliberate effort to shift the tax burden from the wealthy and white to the poor and black. This phenomenon is not new. There is a history of communities that are facing financial exigencies correcting their budget deficits by levying formal and informal taxes on black people. The collateral consequence of formal and informal taxes levied disproportionately on black people includes more potentially violent confrontations with police and responses like the Black Lives Matter Movement. The chapter then considers whether well-intentioned white folks have lent their support to racist taxation, perhaps unwittingly, because the stated purposes of increased taxes satisfy their social desires while it squares with their financial interests to ignore the disparate racial ramifications.
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Conference papers on the topic "Qualification for income tax purposes"

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Ofiarski, Zbigniew. "Principles of Taxation of Interest Income or Discount on Covered Bonds Issued in Poland." In The XX International Scientific Conference "Functioning of Investments Financed from State Resources and from Other Sources in The Countries of Central And Eastern Europe". Temida 2, 2022. http://dx.doi.org/10.15290/ipf.2022.15.

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The rules of taxation of revenues or income from covered bonds issued in Poland may become a significant barrier to the demand for this category of debt securities and, as a result, considerably limit the capabilities of mortgage banks to grant long-term loans for investment purposes. The present study has analysed and assessed the legislation in force in Poland regarding the scope and methods of taxation of interest and discount on covered bonds as a form of revenue or income earned by their holders. The aim of the study is to present various methods of taxation of these revenues or income, determined by the legal status of taxpayers. The thesis verified herein assumes the excessive privileging of non-residents with revenues or income from covered bonds, leading to unequal treatment of the taxpayers who are Polish tax residents. Furthermore, the study demonstrates that the legislator has led to a situation where corporate income tax payers are treated more favourably than personal income tax payers as regards the taxation of interest and discount on covered bonds. The formulated de lege ferenda postulates are intended to significantly reduce these differences in the taxation of revenues or income obtained from the same source. The study uses the legal-dogmatic method and, additionally, the analytical method.
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Joldeska, Irina, and Stevcho Mecheski. "Establishing an Annual Account for Performers of Independent Activity." In 5th International Scientific Conference 2021. University of Maribor Press, 2021. http://dx.doi.org/10.18690/978-961-286-464-4.17.

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The preparation of the Annual account is mandatory for all economic entities in the Republic of North Macedonia. Depending on the type of categorized economic entity, special forms are prepared prescribed by law, in order to summarize them in the Annual account. Performers of independent activity are economic entities that include an individual person – entrepreneur, sole proprietorship an individual person who is engaged in performing agricultural, craft activity, as well as a person who performs a service or free occupation. Accordingly, at the end of the year, it is necessary to prepare an Annual account which contains the Income and Expenses Balance, the Annual Tax Balance for determining the income tax from performing an independent activity and the Income Structure by activities. The main purpose of the paper is to reflect the legislation of a certain part of companies registered in accordance with the law in The Republic of North Macedonia for external reporting and tax purposes. Hence, as a conclusion, the practical preparation of the three forms, implemented in the Annual Account of a sole proprietorship can be seen.
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Çelik, Sabahat Binnur. "Turkey's Direct and Indirect Taxation Policy in terms of Tax Justice." In International Conference on Eurasian Economies. Eurasian Economists Association, 2016. http://dx.doi.org/10.36880/c07.01564.

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Public finance is a branch of science which examines the activities' economic and finance aspects of the public sector. Public finance has three main objectives such as keeping the economy in balance, providing justice in the distribution of income and providing the economic development / growth. State has to create and apply some finance and economic policies according to those objectives. State can use mainly three tools which are public incomes (mostly taxes), public expenditures and public debt for to keep and to protect the economy in balance. While keeping and protecting the economy in balance, state must consider "justice" in every chosen policy. This work's subject is examining the taxation policy according to the types of taxes from the view of "justice in taxation" in Turkey. In order to reach a successful comment about this subject, we will consider the rate of direct and indirect taxes to total tax revenue. If there isn’t justice in taxation, this means that state couldn't apply appropriate policies in a successful way or didn't apply them because of its other purposes. We know that in this century the state is intrusive, effective and very powerful, so we can easily claim that state has responsibility from the lack of justice in taxation. It should not be forgotten that, ensuring "justice in taxation" is so important principle that, Turkish Constitution edited it as an order.
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Reports on the topic "Qualification for income tax purposes"

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Astudillo, Karen, Vicente Fretes Cibils, Carola Pessino, and Darío Rossignolo. Making the Invisible Visible: Applying a Gender Perspective To Strengthen Tax Policy in Latin America and the Caribbean. Inter-American Development Bank, July 2022. http://dx.doi.org/10.18235/0004350.

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Latin American and Caribbean countries have made efforts to ensure that fiscal policies do not cause biases toward women. However, depending on where the tax burden falls, taxes do create gender biases. This technical note has two purposes. First, it provides evidence of how womens economic participation, care responsibilities, and consumption patterns enter into a countrys tax systems, generating invisible biases. Second, it summarizes the main lessons learned through cross-country comparisons that analyze the impact of direct and indirect taxes on gender equality, the progressivity of the tax systems using both income and expenditure as welfare measures, and the impact of tax systems and tax reforms on households depending on their composition and across the income distribution. The note also provides policy recommendations and good practices that will add to the regions efforts to strengthen fiscal policy taking a gender perspective into account. There is no unique approach to achieving gender equity only through gender-sensitive fiscal policies; rather, the path to change will likely be highly dependent on the balance struck between differing political and economic factors and interests. However, should Latin American and the Caribbean countries take on this challenge, not only could they generate more revenue in the future, but the changes should contribute to sustained and inclusive growth, with greater gender equality.
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Occhiali, Giovanni. Implementation Obstacles and Political Appeal of Environmental Taxes in Sub-Saharan Africa: Reflections from Selected Countries. Institute of Development Studies, November 2023. http://dx.doi.org/10.19088/ictd.2023.058.

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Increasing the slow pace of adoption of environmental taxes across low-income countries has become a significant priority among international financial institutions, multilateral development banks, and international donors. Yet little is known about the practical institutional, administrative, and political obstacles that have led to their slow implementation and how they can be made more appealing, especially across sub-Saharan Africa. Based on an extensive literature review and 16 in-depth interviews with ministries of finance, revenue authorities, and other government stakeholders across six African countries, this paper provides some evidence that will support action and research on this theme. While there are differences across the countries covered, a lack of data and analytical capacity to develop effective environmental taxes is a common theme, as well as the historical prioritisation of their revenue mobilisation capacity over their environmental impact. A great variety of government actors with a mandate over natural resources, often with competing policy priorities, coupled with a lack of coordination fora, has also impeded the harmonisation of the environmental charges they levy. These measures are also often perceived to be regressive and to pose an obstacle to industrial development, lowering their appeal, given that poverty reduction and employment creation are an overarching priority. Nonetheless, support for introducing specific environmental tax measures exists across the population and policymakers, especially if their revenue can be earmarked for environmental purposes.
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Szwedzki, Roni, Jose Fajgenbaum, Ana Ramirez-Goldin, Héctor Valdés Conroy, Rafael Brisco Couchonal, Juan Felipe Murcia, Diego Fernández Montero, Darinka Vásquez Jordán, and Alejandro Soriano. Country Program Evaluation: Costa Rica (2011-2014). Inter-American Development Bank, January 2015. http://dx.doi.org/10.18235/0010606.

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This document presents the results of the evaluation of the Bank's country program with Costa Rica for the period 2011-2014. This is the fourth time the Office of Evaluation and Oversight (OVE) has provided an independent review of the Bank's program with Costa Rica. The first Country Program Evaluation (CPE) in 2003 covered the period 1990-2001, during which an open trade model was consolidated, leading to substantial foreign direct investment. The second CPE covered the period 2002-2006, in which the country was heavily exposed to external shocks. The third and most recent evaluation, covering 2007-2011, highlighted the difficulty of forging linkages between the mostdynamic sectors and the rest of the economy, and drew attention to the State's dwindling capacity to finance investments as a result of its low tax burden and heavy expenditure rigidities. The evaluation was conducted in accordance with the OVE mandate (document RE-238 corr.) and the Protocol for Country Program Evaluations (document RE-348-2). Its main purposes are to facilitate accountability and identify lessons learned that can enhance the Bank's future program. The evaluation took into account the new country strategy paper models (document GN-2468-6) developed by Management, the most significant practical effects of which were: (i) the de facto separation of the formulation of the country strategy and the programming of operations; (ii) the new emphasis on sector notes; and (iii) the updating of the strategy results matrix and programming documents. The production of this document involved interviews with some 200 people, including the Bank's main counterpart (the Ministry of Finance); sector-level executing units and the staff responsible for them at the ministerial level; as well as civil society organizations, academics, representatives of international organizations in Costa Rica, and the Bank's Representative and Country Office and headquarters staff. OVE is particularly grateful to the participants in the 22 workshops held in the country, and also to the Regional Manager's Office, the Bank's staff in the Country Office, and the people and authorities of Costa Rica for their generous hospitality. To fulfill the goal of analyzing the Bank's work during this strategy cycle, OVE reviewed a portfolio of all loans and technical cooperation programs approved between 2011 and 2014, as well as those approved earlier but mostly executed during this period. The lessons learned from this CPE should to serve as a useful input not only when preparing the next country strategy with Costa Rica, but also for the Bank to further enhance its service to similar middle-income countries, where access to alternative sources of financing presents new opportunities and challenges for the Bank.
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