Anglo-American Corporate Taxation: Tracing the Common Roots of Divergent Approaches

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Cambridge University Press, Sep 22, 2011 - Law
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The UK and the USA have historically represented opposite ends of the spectrum in their approaches to taxing corporate income. Under the British approach, corporate and shareholder income taxes have been integrated under an imputation system, with tax paid at the corporate level imputed to shareholders through a full or partial credit against dividends received. Under the American approach, by contrast, corporate and shareholder income taxes have remained separate under what is called a 'classical' system in which shareholders receive little or no relief from a second layer of taxes on dividends. Steven A. Bank explores the evolution of the corporate income tax systems in each country during the nineteenth and twentieth centuries to understand the common legal, economic, political and cultural forces that produced such divergent approaches and explains why convergence may be likely in the future as each country grapples with corporate taxation in an era of globalization.
 

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Contents

Introduction
1
1 A brief history of early AngloAmerican corporate income taxation
19
Part I Twentieth century and the divergence in systems
47
2 The United Kingdom
49
3 The United States
70
Part II Explaining the divergence
105
4 Profits
107
5 Power
142
6 Politics
188
Part III Conclusion
221
7 1970s to Present A Time of Convergence?
223
Index
250
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About the author (2011)

Steven Bank is a professor of law at the University of California, Los Angeles, School of Law, where he uses history and finance to explore the taxation of business entities in the United States and other countries.

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