Taxation of Corporate Groups
- corporate group members versus corporate groups as taxable entities;
- anti-abuse rules and developments in judicial anti-abuse doctrines;
- costs associated with, e.g., valuation of assets, compliance, and administration;
- how certain core CIT concepts are independent of tax law;
- efficiency, equity, and the protection of existing property rights;
- the firm’s reaction to behavioral control instruments;
- limitations on the use of losses;
- depreciation and amortization rules;
- manipulation of legal characterization; and
- transfer of assets and income.
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About the Author.
List of Abbreviations.
List of Figures.
Introduction: Problem, Approach and Structure.
Chapter 1 The Policy Approach.
Chapter 2 The Taxation of Corporate Groups under the Standard CIT System.
Chapter 3 The Tax Integration of Corporate Groups.
Chapter 4 Policy Guidelines.
Table of Statutes.