Der Mitunternehmeranteil an der Personengesellschaft im Ertragsteuerrecht

2021 ◽  
Author(s):  
Ege-Aksel Kilincsoy
Keyword(s):  
Income Tax ◽  
Company Law ◽  
Tax Law ◽  
Current Income ◽  
Business Partnership ◽  
Recent Developments ◽  
Income Tax Law

Under current income tax law, a partner’s share in a business partnership is not an individual economic asset, but the entitlement to the assets of the company in question. In this respect, the ‘unity of the partnership’ is displaced by the ‘plurality of the partners’. This approach is no longer consistent with recent developments in company law: the company itself is now the owner of its assets. This dissertation first shows the shortcomings in this regard from the perspective of the current tax law. Subsequently, it presents alternatives which are oriented towards the unity of the partnership.

scholarly journals Die verkoop van 'n besigheid as lopende saak: Belasting en arbeidsreg probleme met “voorsienings”

2011 ◽  
Vol 4 (2) ◽  
pp. 433-448
Author(s):  
Suzanne Kieviet
Keyword(s):  
Income Tax ◽  
Tax Law ◽  
Current Income ◽  
Labour Relations ◽  
Contingent Liabilities ◽  
Tax Legislation ◽  
Income Tax Law ◽  
Prospective Employer ◽  
Work Security ◽  
Tax Deduction

The amounts set aside for the provision for employee-related contingent liabilities, such as the provision for leave pay, are often considerable. According to current Income Tax law, it is highly unlikely that the former employer (seller) will enjoy a tax deduction. Furthermore, it is also unlikely that the prospective employer (buyer) will enjoy a tax deduction. In contrast to this, both the former and prospective employers are held liable according to the Labour Relations Act in cases where a business is sold as a going concern. This article concludes that the Draft Taxation Laws Amendment Bill 2011, as envisioned, finally provides clear tax legislation, but still needs to be aligned with the objectives of the Labour Relations Act. In doing so, contradictory legislation will be avoided, thus facilitating the transfer of businesses and achieving the protection of employees’ work security.

A STUDY OF THE IMPACT OF SPECIAL INTEREST GROUPS ON MAJOR TAX REFORM: AGRICULTURE AND THE 1913 INCOME TAX LAW

2008 ◽  
Vol 35 (2) ◽  
pp. 71-100 ◽  
Author(s):  
Douglas K. Barney ◽  
Tonya K. Flesher
Keyword(s):  
Quantitative Analysis ◽  
Income Tax ◽  
Income Taxes ◽  
Tax Law ◽  
Special Interest Groups ◽  
Congressional Debates ◽  
Farm Population ◽  
Income Tax Law ◽  
State Income ◽  
The Impact

Farmers have benefited from unique tax treatment since the beginning of the income tax law. This paper explores agricultural influences on the passage of the income tax in 1913, using both qualitative and quantitative analysis. The results show that agricultural interests were influential in the development and passage of tax/tariff laws. The percentage of congressmen with agricultural ties explains the strong affection for agriculture. Discussion in congressional debates and in agricultural journals was passionate and patriotic in support of equity for farmers. The quantitative analysis reveals that the percentage farm population was a significant predictor of passage of the 16th Amendment by the states and of adoption of state income taxes in the 20th century.

Federal Income Tax Law

1927 ◽  
Vol 26 (2) ◽  
pp. 230
Author(s):  
George M. Morris ◽  
Roland R. Foulke
Keyword(s):  
Income Tax ◽  
Tax Law ◽  
Federal Income Tax ◽  
Income Tax Law

Distributional Effects of Taxes and Benefits in Korea

2009 ◽  
Vol 24 (1) ◽  
pp. 59-80
Author(s):  
Sung Myung Jae ◽  
Jeon Byung Mok ◽  
Jun Byung Hill
Keyword(s):  
Simulation Model ◽  
Income Tax ◽  
Tax Revenue ◽  
Tax Law ◽  
Current Version ◽  
Middle Income ◽  
Absolute Value ◽  
Consumption Decisions ◽  
Income Tax Law ◽  
Income Taxpayers

A Simulation model has been developed in Korea, named Korea Institute of Public Finance Simulation Model (KIPFSIM), which aims to estimate the effects of taxes and transfers in Korea. The current version of KIPFSIM adopts a statice approach combined with a zero-elasticity assumption that there will be no change in labor supply and consumption decisions even after changes in taxes and transfers. KIPFSIM uses a representative sample from the House-hold Income and Expenditure Survey, compiled and released by the Statistical Office of Korea. Using KIPFSIM, we hypothetical changes in taxes and transfers, which is set to be enacted in 2009 and 2010. We found that the benefit of the income tax cut is concentrated mostly on high-income taxpayers in terms of absolute value, but more on middle-income taxpayers in terms of percentage of the tax burden. Therefore, the new income tax law is considered to strengthen the progressive nature of the tax code and to lower tax burdens and tax revenue. We also found that after-income-tax income inequality, as measured by Gini coefficeint, was slightly worsened, primarily due to the decrease in income tax revenue, whice helps equalize income distribution.

scholarly journals ANALISIS PERHITUNGAN DAN PELAPORAN PPH FINAL PASAL 4 AYAT 2 ATAS BUNGA DEPOSITO DAN TABUNGAN NASABAH PADA PT. BPR MAPALUS TUMETENDEN CABANG TOMOHON

2016 ◽  
Vol 11 (2) ◽  
Author(s):  
Veronica Junisa Lolong ◽  
David Paul Elia Saerang ◽  
Hence Wokas
Keyword(s):  
Service Quality ◽  
Income Tax ◽  
Descriptive Analysis ◽  
Field Studies ◽  
Study Data ◽  
Tax Law ◽  
Income Tax Law ◽  
The Government ◽  
Tax Deduction

Income tax is one of the largest government revenues. Income Tax Law Article 4 Paragraph 2 gives a mandate to the government to impose income tax on certain earnings final. This study aims to determine how the interest calculation and interest reports and final income tax deduction on interest of savings and customer deposits at PT. BPR Mapalus Tumetenden Branch Tomohon. Descriptive analysis was employed in this study. Data were obtained by field studies. The results shows that the calculation and reports of Final Income Tax Article 4 Paragraph 2 on deposit and savings PT. BPR Mapalus Tumetenden Branch Tomohon have compiled with the laws of regulations. Leaders of PT. BPR Mapalus Tumetenden Branch Tomohon should improve the service quality to each customer, so that the customers can increase the amount of savings in bank. Keywords: calculation, reporting, deposit interest, customer savings

scholarly journals ANALISIS PERHITUNGAN DAN PELAPORAN PAJAK PENGHASILAN (PPh) DI P.T BANK SULUTGO

2017 ◽  
Vol 12 (2) ◽  
Author(s):  
Novlicia Putri Utiarahman ◽  
Jantje J. Tinangon ◽  
Dhullo Afandi
Keyword(s):  
Income Tax ◽  
Descriptive Analysis ◽  
Field Studies ◽  
Study Data ◽  
Tax Law ◽  
Government Revenue ◽  
Income Tax Law ◽  
The Law ◽  
The Government

Income tax is of the largest government revenue. Income Tax Law Article 4 Paragraph 2 gives a mandate to the government to impose income tax on certain earnings final. This study aims to determine how the calculation and report income tax  on savings, deposits, giro customer at PT. Bank SulutGo. Descriptive analysis was employed in this study. Data were obtained by field studies. The result shows that the calculation and reports income tax on savings, deposits, giro at PT. Bank SulutGo have compiled with the law of regulation. Leaders of PT. Bank SulutGo should improve the service guality to each customer, so that custumer can increase the amount of savings.Keywords : calculation, reporting, savings, deposits, giro

scholarly journals Le recouvrement de l'impôt et les droits de la personne

2005 ◽  
Vol 24 (3) ◽  
pp. 457-475
Author(s):  
Henri Brun
Keyword(s):  
Human Rights ◽  
Income Tax ◽  
Due Process ◽  
Tax Law ◽  
Canadian Charter ◽  
Section 8 ◽  
Procedural Due Process ◽  
Due Process Of Law ◽  
Income Tax Law ◽  
The Right

Those who like to pay tax are few. Accordingly, income tax is often described as a shame. Of course, the right to enjoyment of property is at stake in the matters of taxation. And the collection of taxation involves also other aspects of the right to substantive and procedural due process of law : right to privacy, to be heard, to unbiassed decision, to professional secrecy... This article contrasts these rights, as they are expressed in sections 5 to 9 and 23 of the Charte des droits et libertés de la personne of Québec and section 8 of the Canadian Charter of Rights and Freedom, with sections 13 to 16 and 38 and following of the Loi sur le ministère du revenu of Québec and sections 159, 231 and 232 of the Canadian Income Tax Act. It finds that it is the application of the income tax law, more than the law itself, that threatens human rights. It concludes that the main benefit of both Charters of rights is to provide a shelter from such unreasonnable application

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