The author felt that a short history of world income taxes including the earlier American eras would provide a strong foundation on which to build the development of the present Federal income tax structure. With this end in view, chapter one is devoted to this background. The rates of taxation and the amounts of income on which these rates are effective have, of course, varied from year to year. The problems arising in connection with these categories are discussed in the second chapter from the standpoint of the different returns filed. The third chapter presents the varied complex problems that arise in the completion of income tax returns. There are many in this connection but the author has attempted to show only the more important. The accountant has been, naturally, a very influential factor in the development of income taxes, especially in connection with their relation to business. This has been shown in chapter four. The final chapter brings out the conclusions drawn from this study along with some brief summary statements.

The basic aim of this diploma thesis is to preset readers with Act. No. 280/2009 Coll., Tax Code, which came into force on January 1st 2011. Others aims are to describe main benefits of the new Tax Code, to find what are the main problems to put into practice and to evaluate the annual activity. The thesis also introduces and explains how to proceed in accordance with the Tax Code and the specific examples of common situations that may arise in tax administration.

The tax audit can be defined as one of the practices of the tax authorities modified by Act No. 280/2009 Coll., the Tax Code. The aim of the tax audit corresponds with the basic aim of the tax administration, which is primarily to establish correctly a tax assessment. This dissertation is focused on the tax audit from the perspective of the fundamental tax administration principles. The presented dissertation is divided into nine chapters, most of which are further subdivided. The first chapter is focused on the determination of the tax audit. In the second chapter, the attention is paid to the constitutional principles controlling the tax audit, mainly to selected regulations of the Constitution and the Charter of Fundamental Rights and Freedoms. The following third chapter is focused on the isuue of good governance principles. The fourth chapter deals with the fundamental principles of tax administration, as expressed in the Tax Code in §5 - §9. These principles are specified as a basis for the next part of the work. Chapters five to eight are dedicated to the tax audit, which is divided into the beginning of the tax audit, the tax rights and responsibilities during the tax audit, the progress of the tax audit and the final chapter is focused on completion of the tax audit. The last chapter is...

The author expose the key points for future tax codification. He recognize the importance of address the legal principles and the dogmatic taxation developed so far, but he warns that they must be of equal importance the new problems have arisen in the area. In addition, he points out the importance of an improvement in the quality of administrative management for the correct application of Tax Law. / El autor expone los puntos clave para una futura codificación tributaria. Reconoce la importancia de abordar los principios jurídicos y la dogmática tributaria desarrollada hasta el momento, pero advierte que deben ser de igual importancia los nuevos problemas han surgido en el área. Además, señala la importancia de una mejora en la calidad de gestión administrativa para la correcta aplicación del Derecho Tributario.

1 Resume in english Fight against tax evasion from a procedural viewpoint This diploma thesis is about fighting against tax evasion from the point of view of procedural tools, which are regulated by Act No. 280/2009 Coll., The Tax Code. The tesis is divided into three main chapters. The first chapter defines basic concepts, essential for understanding the examined topic, particularly the term "tax" and "tax law". The second part of the thesis defines tax administration in general and basic principles of tax administration, which the tax administrator is obliged to follow in detection of tax evasion. The second part of the thesis also defines the concept of tax evasion for the purposes of this thesis. On one hand, it defines it as a crime regulated by the Criminal Code. But also as a conduct under the law, which pursues a purpose, which the legislature did not presume during preparation of the legislation and on the basis of such conduct, the tax is not set correctly, ie. in accordance with the Tax Code. The third part analyzes and examines the individual procedures for tax administration, regulated by the Tax Code. The detection activity of the tax administrator is analyzed in this part of the thesis, as well as local investigation activity carried out by the tax administrator, and effectiveness of these...

This paper utilizes a short-term event study to analyze the stock price reaction of domestic and foreign M&A target firms to the 2014, 2015, and 2016 Treasury regulatory announcements aimed at restricting corporate tax inversions. The results suggest that domestic M&A target firms experience insignificant abnormal returns as a result of the Treasury overlooking tax-favored acquisitions by foreign acquirers of domestic target firms with significant locked out earnings. Meanwhile, foreign M&A target firms experience insignificant abnormal returns associated with the ineffective 2014 and 2015 Treasury regulations and experience significant abnormal returns associated with the highly effective 2016 Treasury regulations. This paper contributes to the existing debate on corporate inversions by highlighting the common techniques used to escape the United States’ tax jurisdiction, as well as shedding light on a hidden inversion alternative that has been largely overlooked by the Treasury’s regulatory actions.

The subject of this diploma thesis is the tax control which can be classified to the financial law sector. The aim of the thesis is a basic description and introduction to the tax control. During writing my diploma thesis I used legal regulation from several legal branches to clarify the tax control and I considered them in the (mutual) context related to the topic of the tax control. For the comprehensive solution of the tax control issue it was also necessary to apply related judicial decisions and literature. I described the findings concerning the tax control in the diploma thesis by using the description and subsequently I deduced certain conclusions by using the deduction method. I also dealt with ambiguous issues of the tax control which I tried to clarify and take legal opinion on them and imply possible de lege ferendae changes. The diploma thesis consists of the introduction where the subject and the aim of the diploma thesis are introduced. The subject of the following chapters is the general part of the tax control, particular stages of the tax control, consequences of the tax control and means of rights protection. The last part of the diploma thesis devotes to the conclusion, including a summary of the diploma thesis and proposed de lege ferendae changes. The above mentioned diploma...

In this thesis I describe the development of the legal frame for a statutory time limit, a period within which an official government authority can assess, reassess, calculate and issue taxes according to the law on Administration of Taxes and Charges (Nr. 337-1992) as amended and consequently replaced by the Tax Code, law nr. 280- 2009. Such time limit is crucial to establish a clear period during which tax can be assessed or a reassessed and issued to a subject with tax duty. After expiration of such time limit tax can no longer be calculated, and the tax proceedings therefore seize, without having the possibility to modify the tax as it was calculated last. The goal of this diploma thesis is to introduce the development of the legal frame for a statutory time limit for assessment and reassessment of taxes in the light of the modern case-law and its effects. The work includes cases from the Constitutional Court as well as administrative courts and it deals with the aftermath of their findings and lists the impact of such findings on private legal practice and by extension also on the tax subjects themselves. The thesis is divided into 8 individual chapters. Chapters 1 - 4 deal with tax proceedings, and time periods generally, time periods for tax administration and the calculation of course of...

The present seminar deals about the last modifications occurred in the Peruvian normativity on tax matter. This analysis focuses on the last modifications occurred on Income Tax, Tax Code, Tax Drawdown regime and Municipal Taxation. / El presente seminario versa sobre las últimas modificaciones ocurridas en la normatividad peruana en materia tributaria. Dicho análisis se centrará en las últimas modificaciones ocurridas en materia de Impuesto a la Renta, a nivel del Código Tributario, en el Régimen de Detracciones de Impuestos y en materia de Tributación Municipal.

The author analyzes a very important issue such as illegitimate tax avoidance. He begins by explaining the content of the concept of illegitimate tax avoidance, and also he points out the differences with other concepts like tax evasion and tax planning. Then, he comments the debate on the use of legal figures which doesn’t belong to Tax Law, in order to solve issue of illegitimate tax avoidance. Finally, he explains the scope and the application of the Peruvian general anti-avoidance rule stipulated in the Peruvian Tax Code. / El autor analiza un tema de suma importancia como es el de la elusión fiscal. Se comienza esclareciendo el contenido del concepto de elusión, diferenciándolo de otros conceptos como la evasión fiscal y la economía de opción. Luego, pasa a recoger y comentar el debate en torno al uso de figuras ajenas al Derecho Tributario para dar solución al problema de la elusión fiscal. Finalmente, pasa a explicar el alcance y aplicación de la cláusula general antielusiva peruana estipulada en la norma XVI del Título Preliminar del Código tributario.