关于信用卡债务的英文文献和翻译 第6页

her/his tax liability significantly. The most highly qualified professional tax experts earn most of their lucrative  fees  by  giving  advice  on  alternative  ways  of  arranging  facts.  In  other  words,  most professional tax planning is little more than the prearrangement of facts in the most tax-favored way (Sommerfeld et al., 1980: 28/1). Even the International Accounting Standard 12, Income Taxes (IAS
12) has suggested exploiting tax planning opportunities through changing the accounting method or arranging  the facts. Under paragraph 30 of IAS 12, tax planning opportunities are actions that the enterprise would take in order to create or increase taxable income in a particular period before the expiry of a tax loss or tax credit carryforward. IAS 12 has mentioned following few examples how, in some jurisdictions, taxable profit may be created or increased:
(a) by electing to have interest income taxed on either a received or receivable basis; (b) by deferring the claim for certain deductions from taxable profit;
(c) by selling, and perhaps leasing back, assets that have appreciated but for which the tax base has not been adjusted to reflect such appreciation; and
(d) by selling an asset that generates non-taxable income (such as, in some jurisdictions, a government bond) in order to purchase another investment that generates taxable income.
Where tax planning opportunities advance taxable profit from a later period to an earlier period, the utilisation of a tax loss or tax credit carryforward still depends on the existence of future taxable profit from sources other than future originating temporary differences (IASB, 2004: 740).

However, Chapter-XI (sections 104 to 107) of the Income Tax Ordinance, 1984 is on “Special
Provisions Relating to Avoidance of Tax” as follows:
• Section 104: Avoidance of tax through transactions with non-residents
• Section 105: Avoidance of tax through transfer of assets
• Section 106: Avoidance of tax by transactions in securities
• Section 107: Tax clearance certificate required for persons leaving Bangladesh.
Appendix-II delineates the Special Provisions Relating to Avoidance of Tax under Chapter-XI of the
Income Tax Ordinance, 1984.

Critical Variables of Traditional Tax Planning in Business
Traditional tax planning is based on maximizing the tax-favored status and minimizing the tax- disfavored status, which are usually as follows:数据结构课程设计-文本编辑器

Tax-Favored Status Tax-Disfavored Status
Ž                                                                                                                                                                                                                                                                                                                Full tax exemptions
Ž                                                                                                                                                                                                                                                                                                                Partial tax exemptions本文来自优.文,论-文·网原文请找腾讯752018766
Ž                                                                                                                                                                                                                                                                                                                Tax credit, rebate, relief, and concession
Ž                                                                                                                                                                                                                                                                                                                Tax deduction permitted at a rate faster than the
decline in economic value of the asset
Ž                                                                                                                                                                                                                                                                                                                Taxable income permitted to be recognized at a
rate slower than the increase in the economic value of the assets cash flow Ž                                                                                                                                                                                                                                                                                                                Special tax assessment
Ž                                                                                                                                                                                                                                                                                                                Tax deduction permitted at a rate slower
than the decline in the economic value of the asset
Ž                                                                                                                                                                                                                                                                                                                Taxable income permitted to be
recognized at a rate faster than the
increase in the economic value of the assets cash flow
Traditional tax planning starts with finding the critical variables for which a simple tax formula as follows may help:

 
Line No.   
Item
 1   Aggregate Income
 2 –  Exclusions
 3 =  Gross Income
 4 –  Allowable Deductions
 5 =  Taxable Income [‘Total Income’ is the legal term used as tax-base]
 6 ×  Tax Rate(s)
 7 =  Gross Tax
 8 –  Tax Credit, Tax Rebate, & Tax Relief
 9 =  Tax Payable 
Draft Version  Please don’t quote.

Since the ultimate objective of traditional tax planning is the minimization of the bottom line – that is, the minimization of the net tax payable – the rules of simple arithmetic suggest that tax planning must necessarily involve the maximization of tax credits/rebates/reliefs, the minimization of the applicable tax rate(s), and the  maximization of deductions and/or exclusions. In other words, the items on all even-numbered lines in the  above formula constitute the critical variables in tax planning. Each of these variables is briefly explained below.

Maximization of exclusions: Exclusions are the incomes which are not included in the tax-base of the  income tax [‘total income’ as defined u/s 2(65), the scope of which is outlined u/s 17 and computed u/s  43 according to the heads of income u/s 20, but to be reported under the heads mentioned in the ‘Form of Return of Income’ (Form IT-GA) u/r 24]. Under section 44(1), any income or class of income or the income of any person or class of persons specified in Part A of the Sixth Schedule shall be exempt from the tax, subject to the limits, conditions and qualifications laid down therein and shall be excluded from the computation of total income. Along with this list under Part A of the Sixth Schedule, Government has issued a number of Statutory Rules and Orders (S.R.O.) u/s迷宫问题-数据结构课程设计
44(4) of the Income Tax Ordinance, 1984 to extend this exclusion list. Few SROs issued u/s 60(1) of the Income-tax Act 1922 are still in force for similar exclusion purpose. The business entities which have been allowed tax holiday u/s 46A or under any SRO are able to exclude their income enjoying tax holiday. See  Appendix-III for a checklist of all these exemptions to date. Through maximizing these exclusions, tax-base and consequent tax liability can be minimized.

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