碩士 / 中原大學 / 會計研究所 / 94 / Abstract
The Alternative Minimum Tax of our country finally, under the expectations of taxation was established by our national excellent tax reform group through adopting and referring the good experiences, failure reasons of other countries' implements of Alternative Minimum Tax and current taxation structure, although the comments were divided into two opposing extremes, but in terms of current financial debt of our country, after the enforcement of Alternative Minimum Tax, it was estimated to enrich national financial taxation with 11 billions approximately, that may be said a cardiac to taxes; in order to allow Alternative Minimum Tax to proceed smoothly in our country, the associated regulations "Income Basic Tax Act" and its related enforcement rules were individually passed on 9th December, 2005 and 23rd May, 2006; however the area of "Offshore Personal Income" which is also a very big part of current taxation, because of lacking mature check instrument and was consequently postponed to 2009 to be included into AMT calculation when applicable. Therefore, this study was conducted under the above mentioned context for related study and analysis, and hopes to contribute to the smooth development of our national Alternative Minimum Tax.
Based on the study and analysis of several advanced countries on the income taxation to Controlled Foreign Company, it showed that each country has unique views about CFCS legislation, and can check the offshore source income of individuals and enterprises at the same time, and these can provide our country as very useful reference to legislate or amend the laws and regulations related to offshore source income, however it was also found that the reason why revenue service organizations are short of mature check instruments and thus decided to postpone the inclusion of offshore income into AMT calculation until 2009 when applicable, is really because the political sensitiveness of our country and our countrymen income is of Territoriality Principle. Therefore this study suggested that upon future legislation or amendment, government should primarily pay attention to change the taxation into Personal and Territoriality Principle, also because the political sensitiveness of our country, suggested that for diplomacy it is necessary to actively open up effective diplomacy and negotiate multilateral tax treaties, revenue service organizations should also set up penalty rules against dishonesty declaration of offshore income from individuals and enterprises, by this way it may only be possible to achieve the fairness state of taxation.
| Identifer | oai:union.ndltd.org:TW/094CYCU5385047 |
| Date | January 2006 |
| Creators | CHERRY HSU, 許嘉欣 |
| Contributors | none, none, 簡俱揚, 鄒翊 |
| Source Sets | National Digital Library of Theses and Dissertations in Taiwan |
| Language | zh-TW |
| Detected Language | English |
| Type | 學位論文 ; thesis |
| Format | 89 |
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