内容正文:
24
24.1 What are Corporations, and Why Do We Tax Them?
24.2 The Structure of the Corporate Tax
24.3 The Incidence of the Corporate Tax
24.4 The Consequences of the Corporate Tax for Investment
24.5 The Consequences of the Corporate Tax for Financing
24.6 Treatment of International Corporate Income
24.7 Conclusion
Taxation of Business Income
1 of 52
1
24
Introduction
On May 4, 2009, Barack Obama proposed to reform the corporate tax system by ending tax incentives for U.S. companies that have invested heavily in overseas operations.
He claimed that these companies were “shirking” responsibilities and were a large factor in the “iniquities of a broken tax system that rewarded firms for creating jobs in Bangalore rather than Buffalo, New York.”
of 52
C H A P T E R 2 4 ■ T A X A T I O N O F B U S I N E S S I N C O M E
2
24
Introduction
In particular, Obama proposed to reform deferral rules so companies will not receive deductions on their U.S. tax returns until they pay the appropriate taxes on their overseas profits. This provision, which would be enacted in 2011, would raise $60 billion between 2011 and 2019.
The second component of Obama’s proposals would raise a total of $87 billion between 2011 and 2019 through more stringent restraints on offshore “tax havens” where tax rates are particularly low.
of 52
C H A P T E R 2 4 ■ T A X A T I O N O F B U S I N E S S I N C O M E
3
24
Introduction
Supporters agreed that the government needs to intervene to “fix” the tax system.
Others argued that instead of creating more opportunities in the United States, Obama’s plan would reduce domestic job creation.
A lower U.S. tax rate on foreign income:
Allows U.S. companies to be competitive in economies abroad where foreign owned companies are subject to lower tax rates, increasing the tax base despite a lower tax rate.
Compensates for a lagging domestic market presence by diversifying its customer base, thereby reducing domestic layoffs due to reduced domes