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Vol 21 No 9 Sept/Oct 2016

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Goode on Commercial Law

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Comparative Income Tax Deferral: The United States and Japan

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ISBN13: 9789041197719
ISBN: 9041197710
Published: November 2000
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £91.00

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Examining the benefits achieved by deferring income or accelerating deductions, this text refers to the income tax systems of the United States and Japan. The United States has been at the forefront of recognizing the time value of money benefit of tax deferral and of devising methods to prevent tax deferral. Japan, on the other hand, is only gradually placing greater emphasis on tax deferral issues, in light of the activities of foreign companies, and the constant introduction of new financial products which take advantage of the tax deferral allowed under Japanese income tax rules.;The book starts with a detailed discussion of the 1948 Cary Brown model and its various interpretations, an understanding of which is key to any analysis of tax deferral issues. The author goes on to provide a comparative analysis of the different tax deferral patterns that can arise under the United States and Japanese income tax systems, and of methods introduced by the United States to eliminate the tax deferral benefit. A history and overview of the Japanese income tax system is included in the appendix.;Principles of tax deferral and time value of money are crucial in an era of globalization in commerce and finance. They cut across all areas of taxation and are particularly important in the context of taxation of derivatives and other financial instruments.

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Acknowledgments. Foreword.
1. Introduction.
2. The Cary Brown Model.
3. Interpretations of the Cary Brown Model.
4. A New Way of Looking at an Old Model.
5. Various Deferral Scenarios.
6. Various Methods in Preventing Tax Deferral.
7. Summary of the Various Methods.
8. Conclusion. Appendix. Bibliography.