En matière de fiscalité, l’Europe s’est construite avec pour seuls buts l’élimination des doubles impositions et des discriminations, l’idée d’une harmonisation qui faisait encore débat dans les années `70 n’étant désormais plus à l’ordre du jour. La mise en concurrence...

This paper investigates the effect at the bank and industry level of a 1996 tax law change allowing commercial banks to elect S-corporation status. By the end of 2007, roughly one in three commercial banks had either opted for or converted to the S-corporation form of organization. Our study...

These comments challenge a recent paper by Professor Reuven S. Avi-Yonah and Mr. Amir C. Chenchinski entitled “Corporate Tax Integration and the Debt/Equity Distinction: The Case For Dividend Deduction.” In their paper, Professor Avi-Yonah and Mr. Chenchinski advance a system under which...

In 1985 New Zealand had a tax system that taxed corporate profits twice, first in the hands of the company and secondly in the hands of the shareholder, known as the “classical system”. The paper suggests how dividends from capital sources ought to be treated if this double taxation is to...

This paper investigates the effect at the bank and industry level of a 1996 tax law change allowing commercial banks to elect S-corporation status. By the end of 2007, roughly one in three commercial banks had either opted for or converted to the S-corporation form of organization. Our study...

One important question facing shareholder-employees of small, closely-held C corporations is how to pay themselves for working in and/or running their corporations. Traditionally, C corporation shareholder-employees have been advised to pay themselves compensation instead of dividends, because...

This essay, scheduled to appear in the 2014 symposium issue of the Chapman Law Review, proposes enactment of a deduction to individuals for distributions received on stock in regular, or "C," corporations when the distributions are reinvested prior to the return date for the year of...

An inquiry into the innate nature of a tax presupposes examination of an intricate web of variables, which on most occasions results into raging debates. For examples, whether a tax on service provider is a tax on service or a professional tax, whether a tax on capital value of assets is same as...

The taxation of dividends is characterized by the fact that the taxable object stems from profits that will usually have already been taxed at the level of the distributing company. If the second layer of taxation at the shareholder level constitutes economic double taxation, to what extent, if...