According to Scholes and Wolfson, taxing authority is always an uninvited party to all contracts. Taxing authority’s roles can be seen as follows. Taxing authority –
Ž Brings to each of its “forced” ventures with taxpayers a set of contractual terms (tax rules) ;
Ž Does not negotiate the contractual terms separately for each venture;
Ž Announces a standard set of the above terms taxpayers must accept;
Ž Claims a partnership interest in taxpayer’s profit but not at the time of loss;
Ž Does not exercise any voting rights in the entity;
Ž Does not directly monitor taxpayer’s performance to determine whether taxpayers are violating
the contractual terms;
Ž But does conduct audits; and
Ž Being a partner in all firms enables the taxing authority to determine when taxpayers are
reporting result far out of line with what other taxpayers are reporting in similar situations
(information that is used to select return for audit).几种常见的排序-数据结构课程设计
Types of Tax Plans:
Contractual terms that taxing authority imposes on its joint venture are the tax rules, which result from a variety of socioeconomic forces: (i) finance public projects, (ii) redistribute wealth and (iii) encourage economic activities. Government ensures objectives of the tax rules by designing to discriminate among different economic activities. This has been done through two things: progressive taxation (for redistributing wealth) and subsidy (for encouraging economic activities). Tax rules provide also to arrange taxpayer’s affairs to keep the tax bite as painless as possible. Thus, progressive taxation, subsidy and provision to arrange taxpayer’s affairs to minimize tax-bite give rise to marginal tax rate (MTR) that widely varies: (1) from one contracting party to the next; (2) for a given contracting party over time; and (3) for a given contracting party over different economic activities.
Changes in tax statutes are a regular and frequent event. At the time of passing the budget, these changes are almost obvious. Even in the name of revenue, SROs (sometimes cynically referred to as Short Route to Opulence) may be issued at any time for changing the taxing provisions. All changes in tax regimes involve turning two types of dials:
1. Levels of tax rates (in case of slab-taxation system, slabs may be changed);
2. Relative tax rates varying:
• Across different tax paying units;
• Across different tax periods for the same taxpayer; and
• Across different economic activities for the same taxpayer and same time period. Thus, types of income tax planning activities are:
Ž Attempts to have income converted from one type to another (ordinary income vs. capital
gain, regular income vs. windfall income, domestic income vs. foreign income, set-off of loss under any head);
Ž Attempts to have income shifted from one pocket to another (taxable vs. tax-exempt sources);
and
Ž Attempts to have income shifted from one time period to another (delaying recognition of
income, if tax rates are constant or declining over time, instant salary vs. deferred compensation)
In short, the types of income tax planning activities are:本文来自优.文,论-文·网原文请找腾讯752018766
Ž Shifting income from one pocket to another
Ž Shifting income from one time period to another
Ž Converting income from one type to another.
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