Accession Number : ADA277851


Title :   The American Law Institutes Reporter's Study of Corporate Tax Integration: A Critique


Descriptive Note : Master's thesis


Corporate Author : GEORGETOWN UNIV WASHINGTON DC


Personal Author(s) : Clement, David B


Full Text : https://apps.dtic.mil/dtic/tr/fulltext/u2/a277851.pdf


Report Date : 14 Feb 1994


Pagination or Media Count : 64


Abstract : The United States has long followed the so-called classical system of corporate equity taxation. Earnings of the corporation are taxed once at the corporate level and after-tax earnings of the corporation are generally subject to a second shareholder level tax. The shareholder tax may be levied close in time to the corporate level tax as in a dividend distribution made form current earnings and profits. Alternatively, the corporation may retain its after-tax earnings for a extended period resulting in stock value appreciation. The shareholder level tax is thus deferred until such time as the shareholder realizes a capital gain on sale or exchange of the appreciated stock. 'The time has come ... for the development of a complete legislative proposal for integration of the individual and corporate income taxes. It would be regrettable if the American Law Institute ... were not a full participant in the debate ...' Twelve years later, despite substantial scholarly debate, discussion in non-legal mainstream periodicals, and general acceptance of corporate integration as a good thing in the abstract, the United States is no closer to implementation of any integration system than it was in 1981.


Descriptors :   *CORPORATIONS , *LEGISLATION , *INCOME , *FEDERAL LAW , *TAXES , UNITED STATES , COMMERCE


Subject Categories : Economics and Cost Analysis
      Government and Political Science
      Sociology and Law


Distribution Statement : APPROVED FOR PUBLIC RELEASE