I would like to devote this thesis to the problem of real estate management and his impact on the income tax base. The main ambition will be to explain the options which investor has during reconstruction of properties or during obtain a new building from a tax perspective. Main options of reconstruction will be described, it is a repair, technical improvement or funding. Second defined possibility is investment in new property, which brings more options as choose a type of construction, location or funding. Next, situation regards current topic as flat construction or solar power plant, will be followed. The end I will devote analysis of model cases.

A research report submitted to the Faculty of Commerce, Law and Management, University of the Witwatersrand, Johannesburg, in partial fulfilment of the requirements for the degree of Master of Commerce (specialising in Taxation) Johannesburg, 2017 / As a result of a weakening and slow global economy and rising debt, many foreign governments are finding it difficult to implement strategies to ensure continued inclusive and sustainable growth. It is based on this troubling perspective of global uncertainty that tax authorities worldwide have unanimously persisted in their fight against tax evasion through the under-declaration of income from foreign assets, the illegal movement of money abroad, the misapplication and / or manipulation of transfer pricing legislation and mistreatments of tax treaties. The G20 Leaders together with the Organisation for Economic Co-operation and Development (“OECD”) have developed standards such as the Common Reporting Standard (“CRS”) for the Automatic Exchange of Information (“AEOI”) between tax authorities to enhance the sharing of information and transparency of information between tax authorities worldwide. South Africa has pledged to implement the CRS and automatically share tax information with other jurisdictions on an annual basis in the fight against tax evasion and avoidance. Of significance, in terms of timing for South African tax residents, is that South Africa has undertaken to be one of the early adopters of the CRS and committed to commence the first exchange of information from 2017. In light of the standards and actions coming into place, it has become clear that before long the likelihood of the South African Revenue Services (“SARS”) and the South African Reserve Bank (“SARB”) detecting tax evasion and avoidance is increasingly high. Based on this, non-compliant taxpayers have a limited timeframe to manoeuvre freely in and what may be their last opportunity to voluntarily disclose these assets and the income derived therefrom to SARS and SARB without facing heavier penalties and possible criminal prosecution. / MT 2018

A research report submitted to the Faculty of Commerce, Law and Management, University of the Witwatersrand, Johannesburg, in fulfilment of the requirements for the degree of Master of Commerce (Specialising in Taxation) Johannesburg, 2017 / Trusts are an essential tool for estate planning. The interest in trust structures by taxpayers has increased over the years and the South African Revenue Services (‘SARS’) and National Treasury (‘NT’) have placed trusts on their agenda due to their perceived tax avoidance resulting from the use of trust structures. Section 7C was introduced into the Income Tax Act 58 of 1962 (as amended) (‘the Act’) in order to curb the avoidance of estate duty. However, the work undertaken by SARS and NT over the years and the insertion of this section in the Act, created an impression that there is avoidance of taxation through the use of trust structures. This study will interrogate the provisions of s 7C in order to determine the effectiveness of this section in curbing the avoidance of estate duty and/or tax through the use of trust structures. The well thought out manner in which this section was drafted and the existence of other tax provisions in the Act which pertain to trusts and the funding mechanisms of trusts suggest that this new inclusion is a convenient and easy manner to monitor the abuse by SARS and NT and subsequently curb the perceived abuse. The interplay of this section with ss 7 and 31 of the Act indicate a risk of unintended double taxation. This and the circumvention options that taxpayers may embark on are matters that may render the section ineffective, although it is evidenced that this section closes that last door that remained open for taxpayers in respect of funding a trust. Key Words: Tax avoidance, estate duty avoidance, National Treasury, SARS, National Budget Speech, Davis Tax Committee Reports on estate duty, Interest-free and low interest loans, Affected Transactions (s 31), Donor attribution rules (s 7), Donations and donations tax, Double taxation. / GR2018

No contexto do sistema tributário nacional brasileiro, uma apuração correta da renda tributável demanda o respeito a princípios abrigados pela Constituição Federal expressa ou implicitamente e, dentre estes, vale citar o princípio da realização da renda que, numa descrição simplificada, auxilia na detecção da capacidade econômica apta a sofrer tributação, uma vez que delineia diretrizes mais concretas para a identificação do momento adequado para que tal tributação se implemente. Este estudo enfoca o momento temporal em que se consideram ocorridos os fatos econômicos individuais que se ajuntam para compor a apuração da renda tributável. Não se trata, portanto, de uma abordagem direta acerca do aspecto temporal próprio da regra-matriz de incidência do imposto de renda, aquele que se identifica normalmente com o término do período de um ano. O tema é abordado com enfoque na tributação da renda, apresentando parâmetros para a conceituação do referido princípio e buscando delinear suas funções, bem como descrever seu âmbito de aplicação no Direito Tributário brasileiro, especialmente no que concerne à apuração do imposto de renda (sobretudo o de pessoas jurídicas). O princípio da realização é examinado sob três diferentes perspectivas. Primeiro, faz-se uma análise dos conceitos de renda (e noções correlatas de realização) fornecidos pelas ciências financeiras e econômicas. Segundo, há uma análise sob a perspectiva histórica que apresenta a evolução deste princípio na Alemanha, nos E.U.A., no Reino Unido e também no Brasil. E, por fim, sob a perspectiva estritamente jurídica, enfocando-se o sistema normativo atualmente vigente no Brasil, discutem-se a posição sistêmica do princípio da realização e as limitações impostas pela Constituição Federal de 1988 e pelo Código Tributário Nacional. Ainda nesta última perspectiva, avaliam-se as funções desempenhadas pelo princípio da realização como integrante dos princípios de contabilidade geralmente aceitos e as relações entre Direito Contábil e Direito Tributário. O princípio da realização é examinado em seus diferentes elementos (cumprimento da obrigação, mudança da posição patrimonial, troca no mercado, mensurabilidade, liquidez e certeza). Por fim, propõe-se uma estrutura para classificação dos diferentes critérios que informam o princípio da realização à luz da legislação brasileira. / In the context of the Brazilian tax system, a correct calculation of taxable income demands respect for the principles sheltered, expressly or implicitly, by the Federal Constitution and, among these, it is worth mentioning the realization principle. In a simplified description, said principle helps in the detection of the economic capacity that is able to suffer taxation, since it outlines more specific guidelines for identifying the right time where taxation may be implemented. This study focuses on the timing of the economic facts that are gathered up to comprise the basis for calculation of the taxable income. It is not, therefore, a direct approach on the temporal aspect of the basic rule of incidence of income tax (aspect which is usually identified with the end of the taxable period of one year). The issue is discussed with focus on taxation of income, showing parameters for the conceptualization of realization principle and seeking to outline its functions, as well as to describe its scope within the Brazilian Tax Law, especially on what concerns the calculation of the income tax (especially the corporate income tax). The realization principle is examined from three different perspectives. First, the study presents an analysis of the concepts of income (and related notions of realization) provided by the financial and economic sciences. Second, there is an analysis on the historical perspective that presents the evolution of this principle in Germany, the USA, the UK and also in Brazil. Finally, under a strictly legal perspective, focusing on the regulatory system currently in force in Brazil, it discusses the systemic position of the realization principle and the limitations imposed by the Federal Constitution of 1988 and the National Tax Code. With respect to the latter perspective, the study examines the functions performed by the realization principle as part of the generally accepted accounting principles and the relations between Accounting and Tax Law. The realization principle is examined in its different elements (achievement of the obligation, change in the property position, market exchange, measurability, liquidity and certainty). Finally, it proposes a structure for the classification of the different criteria that inform the realization principle in accordance with the Brazilian legislation in force.

Debate over the meaning, extension, and proper form of national citizenship is central to American history. This dissertation considers a fundamental obligation of citizenship, the payment of taxes. Focusing on the ratification by the states of the 16th Amendment which made possible the taxation of incomes, it shows how new ideas about the mutual obligations of citizens changed the relationship between Americans and their government with profound consequences for the development of the American state in the 20th century. Ideas of national citizenship contributed to an outcome few at the time expected: 42 of 48 states in a nation steeped in libertarian culture since its founding ratified an amendment awarding the federal government broad, new taxing power. In a detailed analysis of the ratification process in three states - Wisconsin, Virginia and New York - this study demonstrates that ideas about national citizenship structured the politics of ratification. Wisconsin's position in the forefront of Progressive reform and its adoption of a state income tax during the period under study demonstrate the strong affinities between a "new citizenship" and the income tax, factors which led to easy ratification. Virginia's rejection of the amendment was exceptional in a region that largely supported the income tax. In Virginia, a plutocratic political machine, tied to Northeastern industrial interests and strengthened by the recent disenfranchisement of the state's poorer residents, weakened reform efforts and enabled local political elites to ignore the state's strong economic interest in a potential federal income tax. New York's first order economic interests suggested that it would be strongly disposed against the amendment. New Yorkers, then 10 percent of the nation's population, would pay more than 30 percent of an income tax. But unlikely bedfellows among New York's political leadership put forward a patriotic vision of national citizenship. This vision attracted segments of the economic elite, middle-class reformers, and working-class voters to support ratification. The surprising ratification of the 16th Amendment had profound consequences for American federalism. It meant that a minority of wealthy states now owed more to the federal government than their numbers dictated. It enabled a redistribution of income from wealthy states to poorer states that continues to the present day. Ratification also provides a powerful argument against material reductionism in explaining the nature of tax policy and politics in America. It suggests that moral and social considerations - aspects of a nation's political culture, expressed in the American context through evolving ideas of national citizenship - can be critically important in explaining significant changes and movements for tax reform.

After Harberger published his influential paper in 1962, many authors have assessed empirically whether the incidence of the corporate income tax (CIT) falls on capital owners, consumers, or workers (Krzyzaniak and Musgrave, 1963; Gordon, 1967; Arulampalam et al., 2008). Today, there is little agreement among economists about who bears the incidence of the CIT (Gruber, 2007; Harberger, 2008a,b). The reason for the little convincing evidence is that the econometric models used in the literature ignore that the factors that motivate changes in corporate tax policy are sometimes correlated with other developments in the economy and disentangling those effects from exogenous policy changes requires tremendous effort. Using annual information at the industry level for the United States, I propose to investigate the consequences of exogenous changes in corporate tax policy. The identification of these exogenous events follows the work of Romer and Romer (2009, 2010), who provide an extensive analysis of the U.S. federal tax legislation using narrative records from presidential speeches and congressional reports, among other documentations. The results validate the original predictions from Harberger (1995, 2008a). That is, in the short-term, capital owners bear the full burden of the tax. Over time, however, capital owners are able to shift this burden either by raising consumers' goods prices, or decreasing workers' wages. The magnitude of these e ects depends on the degree of capital intensity as well as the access to international markets and the availability of substitutes for the industry under consideration.

According to statistics by the Council of Taiwan, the fertility rate in Taiwan is the world's lowest in 2010. The average number of babies born to women of childbearing age life is 0.9 people. In other words, the average number of children per woman is less than 1. In 2023 Taiwan will enter a negative population growth. Taiwan's population structure becomes a declining birthrate, aging society.The future workforce reduction will greatly affect the competitiveness of Taiwan. The most important factor of decreasing fertility in Taiwan is economics.The majority of people think that raising children has become a heavy burden.Except for a few women, due to personal career planning, work and other factors not yet fertility or infertility .The majority of women still want to have her own children.The most people's attitude of giving birth is reserved because of high unemployment rate ,unsound preschool education system and little child-care subsidy . In the empirical study found that there is no relationship between the fertility rates and the amount of maternity allowance.That is maternity grant can not increase fertility rate. If maternity benefits can not be improved the fertility rate,the fertility incentives of tax breaks are smaller to people.There are some shortcomings of tax incentives for increase the birth,such as revenue loss,tax fairness and so on. It is also possible to increase the birth rate had no significant improvement. The government uses tax benefits to increase fertility rate depending on revenue loss and population growth . The amount and range of tax incentives should be calculated carefully in order to make a balance between the revenue loss and population growth.

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ABSTRACT Effective January 1, 1998, Republic of China¡¦s income tax turned from an independent duty to a 2-in-1 system. The move was mainly to eliminate repeated taxation created when it was an independent duty. The move also allowed business tax paid by companies be allocated to shareholders at the same time when distributing bonuses as a deductible item from the combined income tax to be filed by shareholders as individuals, making all business income be levied only once. The new tax system may be good, fair and reasonable, only the poorly prepared maximum deductible amount set by the government to shareholders and the 10% business income tax imposed on pending yield of companies made the new system unreasonable in many ways or kept the system itself from successful implementation. Excessively complicated computing triggered disputes and discontent among taxpayers, making the government taxation even a more difficult task. It is expected that this study, with its discussions and recommendations on the regulations concerning shareholders¡¦ deductible tax rate and 10% business income tax imposed on pending yield of companies in Republic of China¡¦s 2-in-1 tax system, could serve as reference in future amendments waged by the government. As of shareholders¡¦ deductible items, the different times of effectiveness of shareholders¡¦ deductible could create vacuum in leasing plans for businesses, we would like to suggest final accounting estimates of payable or paid income tax into balance of shareholders¡¦ deductible accounts. Owing to the maximum deductible amount set for shareholders, when a company having the income tax paid for the year is different from its financial income or when asked to make up income tax of past years or income tax for pending yield, discrepancy in the definition of income tax given in financial accounting rules and income tax laws would result in deficits in computing shareholders¡¦ deductible rates, making successful allocation less probable. On the contrary, companies eligible for preferential treatments in terms of deductible taxes for investments are exempted from said maximum amount. Further, businesses, either of sole capital or association, having not to establish any shareholders¡¦ deductible account per income tax, are exempted from the maximum amount as well. Besides, it is stipulated in the income tax law that, when a company allocates its yield to directors, controllers as remuneration and bonuses, deductible items must be excluded and totally eliminated. These are all considered to be unreasonable practices as they mean counter -elimination of traditional industry in the Republic of China, making it necessary to review, improve or even revoke the stipulation in the income tax law concerning shareholders¡¦ maximum deductible amount and allocation. In terms of the 10% business income tax imposed on pending yield of companies, the major dispute arisen from the tax reform focuses on the definition of company¡¦s pending yield as specified in the income tax law. Pending yield computed per Art. 66-9 of the income tax law is different from the pending yield given in the financial accounting rules and business accounting law on one hand, on the other, is differs from the text of other provisions of the income tax law. The narrow sense and missing in company¡¦s pending yield defined in the article would allow a company produce pending yield and the 10% business income tax imposed on pending yield could trigger helical effect of additional tax. Further, other issues such as pending yield for stock interests a company is assigned to, the problematic tax deduction for deductible shares of overseas Chinese and foreign shareholders for pending yield, listing of deduction loss reserve for overseas investment when computing pending yield overseas investments conducted by companies as approved by competent authorities, failure to listing pending yield as deduction by a company adjusting or negotiating on adjustment of revenue with tax offices are all unreasonable issues created by the 10% business income tax. Besides, statistics indicate that the 10% business income tax imposed on pending yield of companies does not mean help when it comes to state tax income, it only triggers entangled administrative tasks and disputes. This suggests that the 10% business income tax imposed on pending yield of companies needs discussion or revocation. Finally, we like to discuss the medium and small companies in the Republic of China because of organization scale or cost factor that keep them from establishing sound accounting systems and internal controls that eventually would result in false registered capital, misappropriation of company loans, tax evasion by illegal issuance or access to invoices, the lack of books or even 2 books. The written review system implemented by the government is only created by the lack of manpower and as a way to simplify the procedure. The system allows that businesses having revenues of not exceeding a specific amount and with income subject to allowable adjustments and net yield rates at specific levels be exempted from submitting books, as approval would only be granted on written documents Besides, difference between the revenue subject to allowed adjustment and the revenue registered on books would be listed as deduction as pending yield. Such a system will never invite medium and small businesses establish sound accounting systems and internal controls and become an unfair system to businesses having books and filing their tax and, consequently, needs further discussion and improvements. Key word¡GIntegrated income tax system , Shareholder deductible tax , Undistributed surplus earnings

Fairness and justice are important goals and cores values for pursuing an effective taxation system. However, for certain economic and social purposes, our nation implements extensive and long period tax deductions causing constant doubt of the equality of taxation. The tax deduction policies may be equitable to the past, but with the change of the environment, should the government carefully examine whether the result of the tax deductions has affected the fairness, justice and fiscal of the nation. If these deductions have already impaired the welfare of the nation, it is necessary to revise the taxation system and reconstruct the public value. The Legislative Yuan has passed ¡§Fundamental Regulations of Income Tax¡¨ also named ¡§Alternative Minimum Taxation, AMT¡¨ by the end of 2005. It is the first tax regulations passed by the Legislative Yuan in the last two decades. These regulations limit the deductions and compensate the deficiency of unfairness. Thus, this research will focus on taxpayers¡¦ recognition and support of the tax reform after the regulations are executed. Should people promote more tax reforms if outdated deductions exist? Therefore, by combining the questionnaires with the empirical analysis, gathering related discoveries and opinions, this research leads to a practical suggestion and provides a reference with the tax authorities to amend the tax deduction policies. According to the result, the tax experts and professionals agree that AMT meets the needs of tax equality and justice. Besides, nearly 60% of the interviewees think AMT is beneficial to our nation¡¦s finance. However, people recognize that negative effects and problems with the implementation of AMT should be overcome. People also highly expect to modify the outdated tax deductions. In conclusion, our research provides the following suggestions: 1. To thoroughly review and revise the outdated tax deductions promptly. 2. To review and amend the extent of the income tax deductions. 3. The review of investment tax credit is the main purpose of our tax reforms. 4. To prevent the incentive of tax evasion and discuss regularly about the existence or abolition of the AMT.