Abstract
In other chapters of this book, the corporation income tax and its integration with the individual income tax are dealt with in the context of a closed national economy. Those chapters assume that only one country is involved and that the corporation and its shareholders are residents of that country and therefore subject to its tax jurisdiction and no other. This chapter, in contrast, will consider the special problems that arise when more than one country is involved—for example, when the corporation is a resident of one country and the shareholder is a resident of another.
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Notes
Butters, “Taxation, Incentives, and Financial Capacity,” 44 American Economic Review, Papers and Proceedings 504, 506 (1954).
Surrey, “The United States Tax System and International Tax Relationships,” 12 Canadian Tax Journal 460, 463 (1964). The Carter Commission, rejecting integration at the corporate level as providing unwarranted relief to nonresident shareholders, also rejected the possibility of overcoming this by increasing the withholding tax on dividends to such shareholders. “Such a substantial withholding tax, regardless of the underlying circumstances, would obviously be unacceptable to some of the countries with which it would be necessary to renegotiate tax treaties.” Canada, Royal Commission on Taxation, 4 Report of the Royal Commission on Taxation 44.
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© 1982 Springer Science+Business Media New York
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Norr, M. (1982). International Aspects. In: The Taxation of Corporations and Shareholders. Springer, Dordrecht. https://doi.org/10.1007/978-94-017-4502-4_7
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DOI: https://doi.org/10.1007/978-94-017-4502-4_7
Publisher Name: Springer, Dordrecht
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