The Taxation of Controlled Foreign CorporationsVictoria University Press for the Institute of Policy Studies, 1987 - Business & Economics - 67 pages Study on the taxation of controlled foreign corporation in New Zealand with reference to other country's approach. |
Common terms and phrases
accounting period active business income adopted associated persons attributed avoid tax black list captive insurance companies resident controlled corporation controlled foreign corporation corporate and non-corporate corporate shareholders corporate tax corporations resident country of residence definition Finance Act 1984 foreign base company foreign company foreign corporation legislation foreign corporation rules Foreign tax French grey list income of controlled Income Tax Act indirect ownership rules inter-corporate dividend exemption jurisdictional approach legislating country Legislation applies liable to taxation located low tax jurisdiction minimum shareholding requirement nominal tax rates non-corporate shareholders non-resident shareholders number of shareholders passive income place of management problem profits rates of tax reason rebuttable presumption resident shareholders revenue authorities section 84 shareholders having control shares held tax avoidance tax countries tax haven tax system taxpayers threshold transactional approach transfer pricing types of income United Kingdom legislation United Kingdom rules voting power vulnerable white list Zealand Income Tax Zealand resident