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1

Beckett, Neal Peter. "Combating abusive EU corporate income tax practices". Thesis, Brunel University, 2016. http://bura.brunel.ac.uk/handle/2438/13492.

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This thesis examines the concept of EU corporate tax abuse in light of the tensions between the protection of EU Fundamental rights and the susceptibility of those rights to abuse. Consideration is given to the major tax abuse practices and arrangements, accompanied by analyses of the responses of a selection of EU member states, and the role and impacts of judicial, state and commercial stakeholder interests. Consequent upon an examination of why past proposals have failed to attain either policy adoption or policy success, it is suggested that the legal concepts of abuse of rights, substance over form and proportionality may be of value in assessing and validating a corporate tax abuse proposal. It will be argued that Member State tax rules and policy initiatives to date have been unsuccessful in eradicating the effects of corporate tax abuse deriving from the exploitation of Fundamental Freedoms and that this failure is attributable to reasons of poor transactional data lineage and disclosure, unresolved political and judicial conflicts between balancing Member State rights with the Internal Market ideal and from a corporate culture that is incentivised to circumvent tax rules with limited recourse. Following an assessment of whether reform should focus on transactional based tax rules or on a broader legal framework to induce taxpayer behavioural changes, it is contended that EU corporate tax abuse can be addressed by rejecting the traditional ideals of tax harmonisation, formulary apportionment, and principles or rule-based tax law approaches as a complete solution. An effective scheme of reform should instead be based on Enhanced Disclosures and Attestation incorporating country-by-country reporting, additional reporting metrics and legal attestations, underpinned by civil and criminal penalties.
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2

Van, Zanten Marie-Louise. "Tax collecting practices : a comparison between antiquity and the modern age". Diss., University of Pretoria, 2016. http://hdl.handle.net/2263/60527.

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South African policymakers are challenged by the limited resources that can be consulted in the field of tax policy proposals that address the needs of the public. Despite the importance of studying tax history as a reference for modern tax systems, decisions regarding current tax collection policies in South Africa have not been informed by effective historical policies. It is imperative that historical tax policies be studied to identify tax policies that produced the desired or intended results, which could then serve as a benchmark for South African tax collection policies. The purpose of this study was to compare the current South African tax collection policies with efficacious tax collection policies implemented in ancient China, Egypt, Greece and Rome. Both similarities and differences between the ancient policies and current policies were found and possible improvements that could contribute to optimising the effectiveness of South African tax legislation were highlighted. The research conducted for the purpose of this study confirmed that similarities exist between current tax collection policies implemented in South Africa and those implemented in ancient civilizations. One particular improvement that South Africa could adopt is to revise the policy relating to the progressive tax system to ensure that all South African citizens, irrespective of their ability to pay, contribute, as was the case in Ancient Egypt. Processes could be implemented to hold the government accountable for the responsible and transparent spending of tax revenue according to the tax budget, as applied by the ancient Romans. It was also determined that the policies regarding tax refunds should be applied by SARS in terms of the relevant legislation and in the pursuance of a fair and stable tax system. By adopting any of the efficient tax collection policies of antiquity, South Africa could initiate steps to optimise the effectiveness of the tax system.
Mini Dissertation (MCom)--University of Pretoria, 2016.
Taxation
MCom
Unrestricted
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3

Saffie, Francisco. "Taxes as practices of mutual recognition : towards a general theory of tax law". Thesis, University of Edinburgh, 2014. http://hdl.handle.net/1842/9589.

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The thesis tries to provide an answer to the problem of tax avoidance. For this purpose a reinterpretation of taxes as practices of mutual recognition is defended. The conception of taxation and tax law defended in the thesis contrast sharply to the merely instrumental or functional conceptions of taxation and tax law that dominates today’s common understanding of taxation and tax law. The thesis lays out the basis for a new general theory of tax law, but does not develop in detail each of the elements of such a theory. The thesis first lays out the problem by analysing different definitions of tax avoidance, tax evasion, and tax planning, as well as their shortcomings. From that discussion, it emerges that the ways in which tax avoidance has been conceptualised are not only unclear but they also fail to produce any relevant insight into the problem of tax avoidance. The thesis then relates those shortcomings to what it calls the classical paradigm of tax law, which leads, in turn, to the contemporary general theory of tax law. A combination of these conceptions – of the substance (function) and form of tax law – explains that the structure of tax law is based on a conception of the obligation to pay taxes in which there is space for tax avoidance. The thesis argues that, in doing so, the purpose of tax law is defeated. Recent alternatives to the contemporary general theory are also analysed and critically evaluated. The second part of the thesis develops the positive aspect of the argument, in three connected moves. First, an argument is provided to prove that both liberal egalitarian and luck egalitarian theories of justice are not able to offer an answer to tax avoidance because they consider taxes and tax law to be mere instruments for redistribution. Second, a substantive reinterpretation of taxation as a practice with an internal good is presented, in which mutual recognition is defended as taxation’s internal good. Finally, an argument for the thesis that the best possible understanding of tax law requires us to interpret it as a teleological institution is provided. With this positive programme, the thesis aims at providing a superior alternative to the merely instrumental conception of taxation and tax law that derives from the classical paradigm presented at the outset. Its superiority is evidenced by the fact that the alternative provided can offer us the conceptual resources to understand the problem of tax avoidance and hence of what tax law is about.
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4

Rowlings, Douglas. "A corporate failure prediction model for non-financial South African corporates incorporating best practices used by the credit industry". Master's thesis, University of Cape Town, 2016. http://hdl.handle.net/11427/20439.

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In the context of the current macroeconomic environment there is an expectation of an increase in South African non-financial corporate failure, where advance prediction thereof will become even more important. A number of South African non-financial corporate failures have occurred following the financial crisis. In addition, South Africa experienced a watershed moment with the first default on a non-financial corporate bond in 2013. At the same time, with the adoption of the International Financial Reporting Standards (IFRS) framework there have been significant advances in the quality of financial information which should improve its usage in predicting corporate failure. This study used the latest sample to date of listed South African non-financial corporates that met the definition of failure but limited the universe of financial information to that which was prepared under IFRS. At the same time, adjustments were made to the financial data based upon pre-selection of independent credit statistic variables most commonly used in ranking relative credit risk for non-financial corporates. Additionally, equity market price data was introduced into the model to add a forward-looking information consideration. This resulted in an eleven variable model where differentiation of corporate failure was facilitated through the use of multiple discriminant analysis.
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5

Gabrielson, Hans M. "White goes black? : "Grey/black" enterprise practices' impact on "white" enterprises in Swedish public discourse". Thesis, Högskolan på Gotland, Institutionen för humaniora och samhällsvetenskap, 2012. http://urn.kb.se/resolve?urn=urn:nbn:se:hgo:diva-1455.

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6

Swart, Sander Laurent. "Internationalization and tax avoidance practices of publicly listed firms within the European Union:The influence of board independence". Thesis, Uppsala universitet, Företagsekonomiska institutionen, 2018. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-347195.

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The main aim of this research is to investigate if large multinational firms publicly listed in the European Union avoid more taxation than less international firms. Furthermore, the composition of the board of directors in terms of independence is considered as a potential moderating influence. I perform Pooled OLS regressions on a 2008-2016 sample of 5,118 firm-year observations, incorporating 669 firms from 21 countries. The results show a negative influence of the level of internationalization on tax avoidance, and this relation is found to be weakened by board independence.
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7

Búry, Tomáš. "Daňová konkurence v USA a v Evropské unii". Master's thesis, Vysoká škola ekonomická v Praze, 2013. http://www.nusl.cz/ntk/nusl-199707.

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The subject matter of the thesis is a comparative analysis of the possibilities of tax competition in the USA and in the European Union. It aims to compare the extent and form of the tax competition within these systems. The thesis consists of five parts. At the beginning, the term tax competition is examined and the possibility of a distinction between fair and unfair tax practices is explored. In the next part the analysis of the US tax system with a focus on competition in the area of direct and indirect taxation is carried out. The third part provides similarly structured analysis of the tax competition in the EU. The fourth part presents the evaluation and the comparison of the tax competition in both systems. The final part concludes with certain normative recommendations for the future of the EU tax system which are made with respect to their applicability for current deliberation of the reform of the taxation in the European Union. The performed analysis yielded interesting results. Contrary to the expectations, it was determined that the tax competition in the US was more intense than in the EU and the tax practices used by some US states included at least the same level of unfairness as those used by some member states in the EU.
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8

Sabri, Yasmine. "Mail-Returns Process Optimization Using Lean Thinking Principles at The Swedish Tax Agency". Thesis, KTH, Industriell produktion, 2011. http://urn.kb.se/resolve?urn=urn:nbn:se:kth:diva-98792.

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Lean Thinking has been widely implemented in various industries in the production context. Lately a number of companies in the service sector have developed lean systems within their organisations to improve efficiency, productivity, and quality of their services. In our study we are putting forward an approach for operational excellence using Lean Thinking principals in the public service context. The study was performed at the Swedish Tax Agency and the main process examined was mail-returns handling process, the main goal was to improve business process by eliminating non value adding activities within the mail-returns handling process. A thorough investigation of the Swedish Tax Agency process was carried out, primary (core) business process was identified. We examined the supporting processes and how they can affect the primary process performance, and we defined the activities associated with mail-returns handling process and the costs incurred, which led to having a fact-sheet that examined the entire process. Process mapping for the current state was carried out and Root Cause Analyses was performed. We identified root causes of the problem and process elements with high improvement potential, and we presented an optimisation proposal for the current state. Based on the optimisation proposal, an improvement proposal for the whole process was developed. Some of the notable attributes of this redesigned strategy were substantial cost savings and reduced process time. The proposal was approved by the Swedish tax agency and practical implementation is initiated.
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9

Tilkian, Guilherme. "O princípio da confiança legítima sob a perspectiva das práticas reiteradamente observadas pelas autoridades administrativas em matéria tributária". Universidade de São Paulo, 2014. http://www.teses.usp.br/teses/disponiveis/2/2133/tde-20012015-114657/.

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Este trabalho versa sobre a aplicação do princípio da confiança legítima no Direito Tributário brasileiro, com foco no art. 100, inciso III, do Código Tributário Nacional (CTN), que trata das práticas reiteradamente observadas pelas autoridades administrativas. Parte-se da origem do princípio, aproximando a investigação por meio do princípio da segurança jurídica, da certeza do direito e da irretroatividade; em seguida, diferencia-se a proteção da confiança da boa-fé objetiva e prossegue-se pelo princípio da legalidade e a evolução jurisprudencial a respeito da conservação positiva ou negativa dos atos eivados de vícios quando deles se originaram direitos. Foca-se, então, nos requisitos para a configuração da confiança digna de proteção e os mecanismos de proteção positiva ou negativa dessa confiança. Desse ponto em diante, o estudo passa a desenhar a proteção da confiança legítima nos atos do Poder Executivo, por meio da análise do art. 100 do CTN, como fonte secundária de direito tributário. Conceituam-se as normas complementares, a origem e sua função, para então proceder-se ao exame específico das práticas reiteradamente observadas pelas autoridades administrativas e sua relação com o princípio da confiança legítima. Em seguida, analisa-se o parágrafo único do art. 100 do CTN para avaliar se são corretas a não atualização monetária da base de cálculo do tributo e a admissão de retroatividade parcial dos efeitos do reconhecimento da ilegalidade da prática administrativa em que confiou o contribuinte. Examina-se, de início, se a inércia da Administração Pública acerca de lançamento cuja homologação se dê de maneira tácita seria um silêncio positivo a configurar prática reiterada suficiente para dar respaldo à proteção do parágrafo único do art. 100 do CTN. O estudo avalia se, no caso dos tributos indiretos, pela impossibilidade de o contribuinte transferir ao consumidor a exação, justificaria uma proteção maior do que aquela conferida pelo próprio parágrafo único do art. 100 do CTN. Por derradeiro, a norma do art. 146 é confrontada com a do art. 100, inciso III, ambos do CTN, para fins de estabelecer os campos de aplicação de uma e de outra e em que medida elas se relacionam com a proteção da confiança legítima.
This work deals with the application of the principle of legitimate expectations in Brazilian tax law, focusing on Article 100, section III of the Brazilian Tax Code, which deals with the practices observed repeatedly by administrative authorities. The proposed scientific part of the origin of the principle, approaching research through the principle of legal security, legal certainty and non-retroactivity. Then differentiates the protection of reliable objective good faith and goes by the principle of legality and judicial developments regarding conservation (positive or negative) of the acts riddled with addictions when their rights originated. Focuses, then, on the requirements for setting up trust worthy of protection and the protection mechanisms positive or negative that trust. Thereafter the study is to draw back the protection of legitimate expectations in the acts of the Executive, through the analysis of Article 100 of the Internal Revenue Code, as secondary sources of tax law. Conceptualize themselves supplementary rules, the origin and function, down to the specific scope of practice repeatedly observed by the administrative authorities and their relation to the principle of legitimate expectations. Then we analyze the sole paragraph of article 100 of the Internal Revenue Code to assess whether it is correct not to monetary base tax calculation and admission of retroactivity of the effects of partial recognition of the illegality of administrative practice that relied on the taxpayer. Turning to specific issues initially analyzed is the inertia of public administration, which tacitly approves taxes charged for approval, would be a positive silence configuring repeated practice enough to give birth to protect the sole paragraph of article 100 of the Tax Code national. The study evaluates whether, in the case of indirect taxes, the inability of the taxpayer to transfer the consumer the exaction would justify greater protection than that afforded by the sole paragraph of article 100 of the Internal Revenue Code. Finally, the norm of Article 146 is confronted with Article 100, item III, both of the National Tax Code, for purposes of establishing fields of application of one and the other and the extent to which both relate to the protection of legitimate expectations.
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10

Kan, Kwok-kin Terry, e 簡國健. "Exploring teachers' perceptions and practices in implementing the AL TAS for practical chemistry in Hong Kong". Thesis, The University of Hong Kong (Pokfulam, Hong Kong), 2000. http://hub.hku.hk/bib/B31961654.

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11

Kan, Kwok-kin Terry. "Exploring teachers' perceptions and practices in implementing the AL TAS for practical chemistry in Hong Kong". Hong Kong : University of Hong Kong, 2000. http://sunzi.lib.hku.hk/hkuto/record.jsp?B2240093X.

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12

Wynter, Carlene Beth. "Property tax administration in practice : a case study of the Portmore Municipality, Jamaica". Thesis, University of Exeter, 2014. http://hdl.handle.net/10871/17580.

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The objective of this study is to obtain an in-depth understanding of the practical working of property tax administration in Jamaica. It highlights the major enforcement and compliance practices along with how the invisible and underlying interactions of actors in the field shape these practices. It also explores those issues and circumstances along with the existing patterns of interests which have contributed to the continued practice of the central administration of the property tax. The study also emphasizes struggles in the property tax field between the various players: the tax authority, the politicians, the developers, the local authorities, the central government and the taxpayers and how each one uses its capital to maintain or dominate its position within the property tax field. The findings revealed that there were various tensions and struggles among the different players within property tax field in Jamaica. The players in the field used their ‘capitals’ to maintain, dominate and or attempt to make changes to the property tax rules. The findings suggest that some property tax enforcement practices were the means through which these tensions were manifested and resolved or on the other hand, the tax authority attempted to use the current practices as hidden agendas to highlight those tensions in order to stand their ground or obliquely suggest changes or even to demonstrate its tacit support of government policies. The findings also suggest that the non-localization of the property tax may be due to varied political interests, mistrust in the local authorities and also the perception by some players that there’s a lack of capital at the local level to manage the tax. Finally, taxpayers’ used their social, economic and cultural capital to resist enforcement and compliance efforts cheating the government of much needed revenues Property tax although not an important national tax is a critical source of revenue for local communities globally. An increased understanding of the working of the practices is beneficial and has implications for both taxpayers and policymakers. The three research questions posed in my study address and highlight the main property tax enforcement strategies and how the tax authority and policymakers use their capital to shape these practices; the extent to which non-localization of the property tax within the Portmore Municipality is influenced by the political dispositions of the players in the field and thirdly the dimensions of property tax compliance and non-compliance in Jamaica. The questions seek to demonstrate how the combination of the actions and interactions of tax administrators, taxpayers, politicians, developers, government bureaucrats reshape administrative practices in the property tax field which have implications for revenue generation and the provision of services. In keeping with the adoption of an interpretive inductive approach, face-to-face interviews were conducted with tax administrators, policymakers, councillors, mayors, taxpayers, members of civil society, a developer and a tax professional. A theoretical framework is created which combines the major themes and theoretical concepts within three strands of literature: tax administration, fiscal decentralization, and Bourdieu’s theory of practice. The structure provides the explanatory lens through which the findings are presented and interpreted. The study contributes to the tax scholarship through an interpretive methodical approach which gives an additional perspective on property tax administration. It answers the call for well-developed tax research dispelling the notion that tax research is adequately dealt with. This study contributes to the tax literature by demonstrating that taxation isn’t just a technical issue; that the legal framework and administrative framework don’t necessarily coincide with practice; that tax practice is shaped by the actions and interactions of players in the field, making it a social construction; that players use their power to influence property tax practice and that players actions are conditioned by their background. The study also contributes a conceptual framework for property tax practice.
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13

Přidal, Martin. "Enhancing the Better Corporate Governance Practice: From Accounting Scandals to Tax Risk Management". Master's thesis, Vysoká škola ekonomická v Praze, 2010. http://www.nusl.cz/ntk/nusl-75024.

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Recent accounting scandals and current global financial crisis have brought new demands on the whole corporate world. The call for better corporate governance is strengthening in all business areas including tax. Tax non -- compliance brings substantial risks for both tax payers and tax revenue authorities. The way how companies manage their tax risks can significantly influence their overall financial performance and reputation. The paper deals with issues of tax non -- compliance as a lack of good corporate governance practice. The main goal of the paper is to put tax into the concept of corporate governance. Moreover, the paper deals with the concept of tax risk management as a way of how tax compliance in general could be enhanced and introduces the current international practice in this field.
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14

Brumatti, Flávia Lorena Peixoto Holanda. "As imunidades tributárias e a livre concorrência". Pontifícia Universidade Católica de São Paulo, 2011. https://tede2.pucsp.br/handle/handle/5670.

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Made available in DSpace on 2016-04-26T20:20:27Z (GMT). No. of bitstreams: 1 Flavia Lorena Peixoto Holanda Brumatti.pdf: 745135 bytes, checksum: 49f734af1d6cdb46b982cca7f1f79611 (MD5) Previous issue date: 2011-10-05
This paper is intended to analyze the doctrine of the prospective overruling os the Courts decisions, focused on the principle of the legal certainty. We understand that the Brazilian legal system only has protection mechanisms in cases that there is change of understanding at the administrative or legislative level. However, there is not a way to avoid the changes of understanding in the judiciary level, what may lead to a legal instability in the behavior of citizens. That is because citizens base their behavior according to the positions of the pacified jurisprudence. But, if such positions change abruptly, there is no instrument to facilitate the people have their rights preserved, since the new decision, as a rule, has retroactive effect. In this scenario, we believe that the modulation of the effects of decisions might be used for such cases, so that there is the prospect of the effects of the judgment for all acts performed by citizens, especially in the taxation, preserving, the legal certainty which shall be given by the Government
Este trabalho tem o objetivo de analisar o instituto da modulação dos efeitos das decisões dos Tribunais, voltando a atenção para a segurança jurídica dos cidadãos. Entendemos que o sistema jurídico brasileiro possui somente mecanismos de proteção nas hipóteses em que existe alteração de entendimento na esfera administrativa ou na esfera legislativa. No entanto, não há, atualmente, uma forma de se precaver das alterações de entendimentos do Poder Judiciário, o que pode acarretar uma situação de piora do estado dos jurisdicionados. Isto porque, os cidadãos pautam suas condutas de acordo com os posicionamentos pacificados na jurisprudência. Contudo, se tais posicionamentos são alterados de forma abrupta, a princípio não existe qualquer instrumento que possibilite que os jurisdicionados tenham seus direitos preservados, já que a nova decisão, em regra, possui efeitos retroativos. Neste cenário, entendemos que a modulação dos efeitos das decisões deve ser utilizada justamente nestas hipóteses, fazendo com que haja a prospecção dos efeitos do julgamento, para que todos os atos praticados pelos cidadãos, principalmente na esfera tributária, sejam preservados, garantindo-se, assim, a segurança jurídica que deve ser conferida pelo Poder Público
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15

Okumu, Ibrahim Mike. "Essays on governance, public finance, and economic development". Thesis, University of St Andrews, 2014. http://hdl.handle.net/10023/5282.

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This thesis is composed of three distinct but related essays. The first essay studies the role of the size of the economy in mitigating the impact of public sector corruption on economic development. The analysis is based on a dynamic general equilibrium model in which growth occurs endogenously through the invention and manufacture of new intermediate goods that are used in the production of output. Potential innovators decide to enter the market considering the fraction of future profits that may be lost to corruption. We find that depending on the number of times bribes are demanded, the size of the economy may be an important factor in determining the effects of corruption on innovation and economic growth. The second essay presents an occupational choice model in which a household can choose either formal or informal entrepreneurship or at the subsistence livelihood. Credit market constraints and initial wealth conditions (bequest) determine an agent's occupational choice. Corruption arises when bureaucrats exchange investment permits for bribes. Corruption worsens credit market constraints. Equilibrium with corruption is characterised by an increase (decrease) in informal (formal) entrepreneurship and a decrease in formal entrepreneurship wealth. Since corruption-induced credit constrained households choose informal entrepreneurship as opposed to subsistence livelihood income in the formal sector, the informal economy is shown to mitigate the extent of income inequality. The third essay explains the role of bureaucratic corruption in undermining public service delivery, public finance, and economic development through incentivising tax evasion. The analysis is based on a dynamic general equilibrium model in which a taxable household observes the quality of public services and decides whether or not to fulfil his tax obligation. Bureaucratic corruption compromises the quality of public services such that a taxable household develops incentives to evade tax payment. We show that corruption-induced tax evasion increases the likelihood of a budget deficit, renders tax payable increase counter-productive, and aggravates the negative effect of bureaucratic corruption on economic development.
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16

Mulligan, Emer. "Tax planning in practice : a field study of US multinational corporations". Thesis, University of Warwick, 2008. http://wrap.warwick.ac.uk/1113/.

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The aim of this study is to achieve a better understanding of tax planning in practice, identifying and taking account of the multiple arenas within which it operates, and thereby highlighting its social and institutional dimensions. In the current rapidly changing business and regulatory environment, in which tax is an extremely important source of revenue for governments around the world, an enhanced understanding of tax planning in practice benefits and has implications for taxpayers and tax policymakers alike. The four research questions posed in this study address: the organisation and strategic alignment of the tax planning function in multinational corporations (MNCs); performance measurement of this function; tax risk management; the nature and impact of the relationship between the tax planning function within MNCs and the external environment within which it operates. Empirically this study focuses on US MNCs, primarily in respect of mainstream corporation tax planning. In line with the interpretive inductive methodological approach adopted, face-to-face interviews were conducted with senior tax executives in US MNCs, and tax advisors to such companies. A theoretical framework is developed which combines core themes and theoretical constructs within three strands of literature, namely, tax planning, new institutional sociology and endogeneity of law. This framework provides a powerful explanatory lens through which the findings are presented and interpreted. The role ofpower and powerful actors is an important and recurring theme, and partly explains prevailing tax planning practices through the intensity of professional and social interaction between tax executives. Increasingly tax risk management is more important and there is evidence that this may change the way in which the tax planning function is given strategic recognition and integrated operationally. with business units. The focus on tax risk management results in an isomorphic trend towards conservatism in tax planning, and competitor and peer company influence are significant in shaping tax risk management mechanisms. Measuring the performance of the tax planning function is found to be variable, although there was a view that the effective tax rate (ETR), although an important external measure of corporate performance, was inappropriate as an internal measure. Tax laws are often portrayed as exogenous factors, however this study has found that companies invest heavily in external affairs and direct lobbying to secure changes in the law to suit their purposes; evidencing its endogeneity. Networking costs, reputational risk management and lobbying costs therefore represent non-tax costs that are difficult to measure, but are important components of tax planning activities, overlooked in the current tax planning literature. In addition to the findings themselves this study contributes to knowledge through its interpretive methodological approach which provides a new and rich perspective on tax planning in practice, highlighting some shortcomings of the positivistic approach. It also develops a theoretical framework which uniquely combines theoretical constructs from three strands of literature.
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Ormeño, Pérez Rodrigo Andres. "The tax policy-making process in practice : a field study in Chile". Thesis, University of Exeter, 2014. http://hdl.handle.net/10871/18830.

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The purpose of this research project is to examine the technical, political, social, organisational and cultural ‘practices’ of tax policy making in order to gain an in-depth understanding of certain tax rules in the Chilean context. Consistent with a qualitative interpretivist approach, this study is informed by documents and three phases of face-to-face interviews with a range of actors engaged in the process of (re)making tax regulation. Through the views of a wide spectrum of participants, including policy makers (broadly defined), tax administrators, academics, tax practitioners and taxpayers, theoretical concepts were inductively developed. These concepts were combined with related tax policy literature and Bourdieusian concepts to construct a theoretical/conceptual framework which was later applied in interpreting the findings. The findings reveal how an élite group of agents forms a social space connected with the field of power. In this space, these agents define tax policy, draft legislation and budget for economic effects. This thesis illustrates how these agents mobilise different forms of capital from their respective fields in order to reach and access this social space. Transfer pricing processes highlight the fluidity of these spaces, allowing the access and influence of external forces. The research also shows that other stages are more distant from the field of power. The findings suggest the importance of tax knowledge and information in the development of tax regulation. Tax knowledge and information become a capital at stake which agents struggle to acquire. Empirical data show that the amount of tax knowledge and information in the space relating to the field of power is connected with the content and robustness of the transfer pricing rules under analysis. This research also suggests a high concentration of transfer pricing tax knowledge in very few agents across the bureaucratic, professional services and corporate/business fields. This research also shows the influence of social capital in the tax policy-making field. The findings show that bureaucrats and politicians consult with those connected with them who are subjects of trust. In the particularities of transfer pricing, the findings illustrate the importance of social capital in defining the content of tax rules. Finally, the study also shows how domination and two forms of violence are present and exercised across the tax policy-making field. This is one of only a few studies that have examined the practice of tax policy making holistically, from the very early stages to the application of the rules in practice, broadly contributing in this respect to the tax policy strand of literature. In contrast to previous descriptive and partial studies, this study captures the views of actors responsible for making tax rules. It also contributes to theory development by translating Bourdieusian tools to analyse tax policy making.
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18

de, Wet Mary-Ann. "Seeking deviations from South Africaメs tax treaty policy with respect to treaties in Africa: evidence from the treaty practice". Master's thesis, Faculty of Commerce, 2019. http://hdl.handle.net/11427/31168.

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Since South Africa was welcomed back into the international arena in 1994, there has been a significant increase in the number of tax treaties concluded between South Africa and other Sub-Saharan Africa countries, as part of South Africa’s goal to expand into Sub-Saharan Africa (SSA). The purpose of this dissertation is to determine whether these treaties concluded between South Africa and SSA countries have been influenced by South Africa’s stated tax treaty policy, or have been guided by regional practices or to confirm whether South Africa’s tax treaty practices have influenced any regional models. This dissertation includes a detailed analysis of 18 tax treaties concluded between South Africa and other SSA countries. This analysis is used to identify any significant deviations in these treaties as compared to the OECD Model and the UN Model. The SSA region has several economic organisations that have developed tax models to cater for treaty negotiations of developing countries. These models include the African Tax Administration Forum (ATAF) Model, the Southern Africa Development Community (SADC) Model and the East African Community (EAC) tax agreement. The study observes that South Africa’s tax treaty practise generally follows the OECD Model, but also incorporates certain provisions of the UN Model. The analysis of the 18 treaties as compared to the OECD Model identified 31 significant deviations to the OECD Model, and of these deviations, 22 (71%) align to the provisions of the UN Model. These significant deviations were analysed to determine if they arose from South Africa’s stated positions on the OECD Model, influenced by South Africa’s domestic laws, or arose at the insistence of the other Contracting State, or from other factors. v The findings suggest that of the 31 deviations, the majority (80%) arise out of South Africa’s positions on the OECD Model and from its domestic laws. Further analysis was conducted to determine if these significant deviations were contained in the SSA regional tax models. The findings indicate that the SADC Model has the highest correlation as it includes 87% of these deviations, followed by ATAF (77%) and EAC (71%). An additional analysis, by country per regional body, was conducted on the deviations arising from South Africa’s treaty practices. This analysis indicates that 80% of South Africa’s treaty practices occur in the ATAF Model, 84% in the SADC Model, and 72% in the EAC Model. This analysis found that, on average, 82% of treaties concluded with ATAF member countries, 81% of SADC member countries and 89% of EAC member countries aligned to South Africa’s treaty practices. The high correlation to the SADC and ATAF Models indicates that South Africa’s tax treaty practices have influenced the development of these regional models, and the high correlation between the treaties for each country and region, suggests that the majority of the treaties have been significantly influenced by South Africa’s tax treaty practices. Thus, the conclusion is that the majority of the significant deviations found in South African treaties concluded with Sub-Saharan African countries arise from the South African tax treaty practices which are generally based on the OECD model, with the inclusion of certain provisions of the UN Model. These deviations align with South Africa’s position to the OECD Model and its domestic laws, which form the South African treaty practices. It is concluded that these treaty practices have significantly guided the SSA treaties and suggests that these treaty practices have influenced the Sub-Saharan African ATAF and SADC Models.
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19

Knížová, Štěpánka. "Vliv daňové judikatury na vymáhací řízení v ČR". Master's thesis, Vysoká škola ekonomická v Praze, 2009. http://www.nusl.cz/ntk/nusl-17069.

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Diploma thesis deals with impact of tax practice of the courts on tax collection procedure. The tax collection procedure is an optional part of the tax proceeding and tops the entire process of tax collection. If taxable person fails his tax liability, the tax administrator will be authorized to order a tax execution. Tax administrator follows the act about tax administration. The main object of the thesis was to evaluate the imperfections of this act and express the conclusions about the possibility of judicature to provide enough support of the act's application in praxis. Concurrently was appraised the influence of new procedual act, which was passed and is going to come into effect next year. The conclusions arise from the historical and law analysis.
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20

Edensor, Tim. "Touring the Taj : tourist practices and narratives at the Taj Mahal and in Agra". Thesis, Lancaster University, 1996. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.308989.

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21

Zúñiga, Aleman Laura. "Gaps in the Public Works Tax Deduction Law and its practical application". THĒMIS-Revista de Derecho, 2014. http://repositorio.pucp.edu.pe/index/handle/123456789/108690.

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Abstract (sommario):
The Public Works Tax Deduction Law has been enacted to foster public investment at a local and regional level by including participation from the private sector and through the subscription of agreements with local and regional governments.Nonetheless its noble purposes, in the application field of the Law, normative gaps are put into evidence, which impede its practical application. In the present article, the author shows which are the Law’s deficiencies, while analyzing them and proposing possible solutions.
La Ley de Obras por Impuestos tiene como objetivo principal impulsar la inversión pública de impacto regional y local, con la participación del sector privado, mediante la suscripción de convenios con los gobiernos regionales y/o locales.No obstante su noble propósito, en el ámbito aplicativo de la ley se evidencian ciertos vacíos normativos que dificultan su aplicación práctica. Es así que –en el presente artículo– la autora nos muestra cuáles son estas deficiencias a la vez que, luego de hacer un análisis de las mismas, nos propone posibles soluciones.
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22

Beling, Brenda Leigh. "Tax topics a trainee chartered accountant should be taught : a survey of perceptions in and outside of public practice". Diss., University of Pretoria, 2009. http://hdl.handle.net/2263/25052.

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Abstract (sommario):
This paper presents the results of an e-mail study designed to determine what tax topics are important in terms of a trainee accountant entering the training environment in South Africa. These topics were then compared to the current tax syllabus being taught at universities and accredited institutions. The results indicated that the current syllabus is largely meeting the expectations of people in and out of public practice, though there are some topics that the syllabus setters and educators should consider including and excluding when next reviewing and updating the syllabus. Copyright
Dissertation (MCom)--University of Pretoria, 2009.
Taxation
unrestricted
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23

Akhand, Z. "Tax compliance in immigrant communities : Bangladeshis in the UK". Thesis, University of Exeter, 2019. http://hdl.handle.net/10871/36372.

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Abstract (sommario):
This thesis employs Bourdieu's theory of practice to explore small immigrant business owners' adaptation to the host country's income tax system. In doing this, the thesis applies a sociological perspective in the theorizing and study of their tax compliance behaviour. Drawing on a survey (N=101) and in-depth interviews (N=27) with Bangladeshi family business owners and their tax advisers in the UK, this thesis demonstrates that immigrant business owners' engagement with the host country's tax system is grounded in the sociocultural status they inherit from their country of origin, even though their social class positions in the new society unconsciously condition and impact on how they practise tax compliance. Findings suggest that the power relations inherent in the tax professional-taxpayer relationship act as a critical factor in the reproduction and transformation of immigrant business owners' moral disposition towards compliance with tax laws. The thesis argues that the ways small Bangladeshi family business owners think, feel and act in their approach to tax compliance is likely to differ not only from those of native business communities but also from those of other immigrant communities in the UK.
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24

Clarke, Roger Anthony, e Roger Clarke@xamax com au. "Data Surveillance: Theory, Practice & Policy". The Australian National University. Faculty of Engineering and Information Technology, 1997. http://thesis.anu.edu.au./public/adt-ANU20031112.124602.

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Data surveillance is the systematic use of personal data systems in the investigation or monitoring of the actions or communications of one or more persons. This collection of papers was the basis for a supplication under Rule 28 of the ANU's Degree of Doctor of Philosophy Rules. The papers develop a body of theory that explains the nature, applications and impacts of the data processing technologies that support the investigation or monitoring of individuals and populations. Literature review and analysis is supplemented by reports of field work undertaken in both the United States and Australia, which tested the body of theory, and enabled it to be articulated. The research programme established a firm theoretical foundation for further work. It provided insights into appropriate research methods, and delivered not only empirically-based descriptive and explanatory data, but also evaluative information relevant to policy-decisions. The body of work as a whole provides a basis on which more mature research work is able to build.
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25

Seo, Eunhee. "Teaching Assistants' (TAs) Personal Epistemologies and Their Instructional Practices in U.S. Universities: A Mixed Methods Investigation of International TAs and U.S. TAs". Diss., Temple University Libraries, 2009. http://cdm16002.contentdm.oclc.org/cdm/ref/collection/p245801coll10/id/21769.

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Abstract (sommario):
CITE/Language Arts
Ed.D.
Current teacher education research calls for investigation of the "missing paradigm," the connection between teachers' conceptions of knowledge and learning and their instructional practices. This call has been heeded in the scholarship on personal epistemology that reveals the role of knowledge in learning and instruction within and across various socio-cultural contexts. This study extends the work on the relationship between teachers' personal epistemologies and instructional practices to a previously unexamined population: international and U.S. Teaching Assistants (TAs). Employing a two-phase explanatory mixed methods approach, this study examines the relationship between personal epistemologies and instructional practices of two teaching assistant (TA) groups, international and U.S.-born, in U.S. university contexts. In the first phase of the study, an epistemological beliefs survey was conducted with two groups of TAs, 106 international and 50 U.S.-born, at four large research universities in the Mid-Atlantic States. Their answers were analyzed with a focus on the relationship between group variables and seven dimensions of personal epistemologies. Building on the initial quantitative study results, in the second phase, a qualitative case study was carried out to investigate the relationship between epistemic positions and teaching practices for four TAs representing international and domestic TA groups within two academic disciplines at a public research university in Philadelphia, PA. Forty four undergraduate student data from focus-group interviews and surveys also were collected to examine the relationship between TAs' instructional practices and student opinions about their teaching. The quantitative results showed a significant group difference in the knowledge beliefs domain and the relational views domain (p < .001). In general, ITAs held a higher degree in their beliefs about certainty of knowledge than did US TAs. In addition, US TAs assumed a closer relationship with their students than did the ITAs, while unlike common assumptions, US TAs assumed a higher degree of status differentiation from students than did ITAs. The findings of the qualitative phase of the study revealed that the relationship between TAs' epistemic positions and instructional practices was not fully consistent. In the case of the US TAs, much of the inconsistency of the relationship is explained by the lack of pedagogical knowledge and pedagogic skills, which would enable them to exercise control over the types of instructional approaches that they wanted to implement at a discourse level in class. ITAs' instructional practices were more closely aligned with learning strategies that they had developed through educational experiences in their home countries and with their generalized assumptions about attitudes of U.S. students toward learning. The results also show that ITAs are as qualified and competent instructors in teaching of undergraduate students as US TAs are, and that ITAs' teacher-centered approaches are well received by the students who expect explanation, guidance, direction, and reinforcement on the part of their instructors. In addition, the analysis of TAs' epistemic positions revealed domain specificity as well as group differences to be major compounding factors affecting TAs' professed epistemologies. Pedagogic as well as theoretical implications of the study are discussed.
Temple University--Theses
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26

Rossi, Albane. "Un espace rural en pays d’openfield : appropriation et occupation du sol à Blandy-les-Tours (Seine-et-Marne), du XVIe au XIXe siècle". Thesis, Bourgogne Franche-Comté, 2018. http://www.theses.fr/2018UBFCC031/document.

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Des travaux récents, inscrits dans un processus d’ouverture à la pluridisciplinarité, ont souligné que l’organisation des sociétés rurales ne peut plus être comprise sans prendre en compte leur relation à l’espace. Ces évolutions conduisent aujourd’hui à travailler sur la dimension spatiale des données extraites des sources historiques.Cette étude doctorale repose, en grande partie, sur la mise en parallèle de données textuelles et planimétriques, modernes et contemporaines, intégrées dans un système d’information géographique. Les documents concernés (un terrier de 1508 ; un autre terrier associé à un plan, tous deux datés du milieu du XVIIIe siècle ; le cadastre de 1845 avec son état de section de 1848), en inventoriant parcelles et tenanciers/propriétaires, ont en commun de présenter de nombreux renseignements sur l’organisation de l’espace rural. Ils décrivent cependant chacun une réalité en relation avec les structures sociales et économiques propres à la période dont ils sont issus.En choisissant de travailler à l’échelle micro- historique, c’est la pratique quotidienne et la perception des acteurs qui seront considérées ; le temps long permet, quant à lui, d’analyser les évolutions (permanences ou mutations) intervenues dans l’organisation de l’appropriation et de l’occupation du sol, entre le début du XVIe siècle et le milieu du XIXe siècle
Recent work, part of a process of opening up to multidisciplinarity, has underlined that the organisation of rural societies can no longer be understood without taking into account their relationship to space. These developments are now leading to work on the spatial dimension of data extracted from historical sources.This doctoral study is based, in large part, on the parallel use of modern and contemporary textual and planimetric data, integrated into a geographical information system. The documents concerned (a terrier of 1508; another terrier associated with a plan, both dating from the middle of the 18th century; the 1845 land register with its 1848 section status), by listing parcels and tenant/owners, have in common that they present a great deal of information on the organisation of rural areas. However, they each describe a reality in relation to the social and economic structures specific to the period from which they emerged.By choosing to work on a micro-historical scale, it is the daily practice and perception of the actors that will be considered; the long time allows, for its part, to analyse the evolutions (permanences or mutations) that occurred in the organisation of land appropriation and occupation between the beginning of the 16th century and the middle of the 19th century
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27

Wilkinson, E. K. "Putting children first? : tax and transfer policy and support for children in South Africa". Thesis, University of Oxford, 2010. http://ora.ox.ac.uk/objects/uuid:caa9ec39-982b-4fc6-a343-b3012980d6f3.

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This thesis considers the extent to which tax and transfer policies in South Africa support children between 2000 and 2008. The analyses are carried out using a four-dimensional analytical framework which separates the dimensions of welfare ideology, policy aims, policy instruments and welfare outcomes. This approach is adopted in recognition of the fact that the extent to which tax and transfer policies support children is seen to vary according to the dimension of analysis. The analysis of welfare ideology, policy aims and policy instruments is undertaken by considering key legislative texts, including the Bill of Rights in the South African Constitution, budget speeches and policy documents. Welfare outcomes are analysed at the individual and household level using microsimulation modelling. A microsimulation model for South Africa, SAMOD, is developed specifically for these analyses. The findings of this thesis add conceptual and empirical understanding to the impact of tax and transfer policies on children. Children are found to be supported by policy to some extent, and have been prioritised in reforms to social assistance. However, recent reforms to tax policy have not benefited children and the analyses indicate that child poverty rates in South Africa could be lower than they are at present had the government pursued alternative policy reforms. The construction of the microsimulation model SAMOD is a valuable tool to facilitate future policy evaluation in South Africa. Further development of SAMOD is recommended to continue to progress and enhance debates on policy reforms. In addition, this thesis highlights some key areas for future research including developing further understanding of the patterns of inter and intra-household income allocation and the impact that this may have on poverty measures for different groups.
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28

Lamb, Margaret Anne. "Tax practice in the United Kingdom and the emergence of interrelationships between accounting and the taxation of business profits". Thesis, University of Reading, 1997. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.245024.

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29

Beling, Brenda. "Tax topics a trainee chartered accountant should be taught a survey of perceptions in and outside of public practice /". Pretoria : [s.n.], 2009. http://upetd.up.ac.za/thesis/available/etd-05272009-145116/.

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30

De, Vos Gerhard Johannes. "Generally recognised accounting practice : a critical evaluation of the impact of grap 23 on administrative tax legislation and recommendations". Diss., University of Pretoria, 2009. http://hdl.handle.net/2263/23893.

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Abstract (sommario):
The application of accrual accounting principles is a challenge for public sectors internationally and increases the level of transparency and accountability of management. Taxation authorities are governed by legislation and have to be supported by a sound legislative framework to enable effective administration of taxes and the proper application of the accrual accounting principles. The recent issuing of the accounting standard for taxes and developments relating to the subsequent measurement of tax receivables highlights the ineffectiveness of current administrative tax legislation relating to penalties and interest which does not allow SARS to effectively apply accrual accounting principles. The receipt of taxpayer returns and payments as required by legislation are critical in order to allow the recording of taxes owed in the financial records of SARS. These taxpayer actions can only be effectively influenced by an effective penalty regime. Similarly, the current interest regimes on tax receivables and payables need to be adjusted in order to allow efficiencies and be comparative to market rates and calculation methods. International comparisons of penalty and interest regimes did not indicate a specific standard regime that should be applied, but the United Kingdom identified sound design principles for penalty and interest regimes. A simple standardised penalty and interest regime for all taxes administered by SARS is recommended which meets the identified design principles and supports the accrual accounting principles. The move to accrual accounting is an additional driver for administrative legislative reform which supports the effective management of taxation authorities. Copyright
Dissertation (MCom)--University of Pretoria, 2009.
Taxation
unrestricted
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31

Dokoupilová, Klára. "Vliv daňové judikatury na vyměření a doměření daně v ČR". Master's thesis, Vysoká škola ekonomická v Praze, 2009. http://www.nusl.cz/ntk/nusl-9196.

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Abstract (sommario):
This thesis was focused on the influence of the tax practice of the courts on the assessment of a tax and the retrospective assessment in the Czech Republic. The purpose was to find out if the present law about the tax and fees administration is a sufficient procedural tax norm and if the existing practice of the courts provides us by its interpretation and integral attitude with reasonable juristic certainty of the tax subjects as well as the tax administrator when in the assessment of a tax and retrospective assessment process. Furthermore the new procedural norm which is just being approved these days in law area was examined: if it brings more suitable legal regulations in the selected areas and if it takes into account the conclusions of the practice of the courts. Finally the conclusions which confirmed expectations in the beginning of this thesis were made. The tax administration law can't act as the basic tax norm because its actual reading contains too many deficiencies. Thereunto from the downright analysis arises that the practice of the courts, which is disunited in its resolutions, for ensuring the integral and right procedure of tax assessment and retrospective assessment can't act. The present situation could be improved by coming into enter be of the new procedural tax law -- The Tax Regulation.
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32

Zhang, Gehao. "Invented tradition and translated practices : the career of Tai Chi in China and the West". Thesis, Loughborough University, 2010. https://dspace.lboro.ac.uk/2134/6865.

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Abstract (sommario):
This thesis takes the primary contemporary icons of Chinese tradition –the popular practice of Tai Chi‐and subjects its career in both China and the West, to a series of critical interrogations focusing on three main moments; the invention and (re)imagination of tradition, the practice's migration from China to the West, and its translation by its English practitioners. During the Imperial period, when Tai Chi was defined primarily as a martial art, it was the focus of a sustained struggle between its official deployment as part of the military machine and its practice by clandestine societies and insurgent movement. It was simultaneously incorporated into the push to modernization and promoted as a part of an unbroken cultural legacy that defined the uniqueness of Chineseness in various forms during Republican China, Mao's era and Post‐Mao era. The thesis also looks at the key figures and the process of institutionalization and indigenisation as the practice generated its own national professional associations and competitions in England since 1940s. Based on ethnographic research in the Midlands, the thesis explores the contending understandings of Tai Chi among its English practitioners. It explores the ways in which British instructors locate themselves within an ‘authentic' tradition by way of a latent lineage system. This allows them to maintain their own personal commitment to Tai Chi as a martial art conflicts while working with the market drive for mass participation based on concepts of relaxation and alternative therapy and medicine. The ethnographic research also explores the ways that students in Tai Chi classes translate it into an indoors practices with an outdoors imagination, and as a bodily discipline with a spiritual basis, and how they construct their understanding of this spiritual dimension by drawing on polysemic interpretations of oriental conceptions such as Yin, Yang and Qi rather than the standardised references to Taoism in the public representations.
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33

Bernard, Ladale Lemoine. "District and School Leadership Perceptions of School Turnaround and Teacher Advancement Program (TAP) Reform Practices". Thesis, University of Louisiana at Lafayette, 2019. http://pqdtopen.proquest.com/#viewpdf?dispub=10846513.

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Abstract (sommario):

With an increased focus on school accountability and school improvement, efforts to quickly improve or turnaround low performing schools are on the rise. School turnaround is a complex concept with a myriad of social, political, and economic aspects (CPRE, 2013, p. 8). While each school is different, there are generally several practices and changes, that if addressed will result in quick improvements among most low performing schools. This dissertation addressed perceptions of district and school leaders, the importance of climate and culture in the turnaround process, and the support needed to sustain the positive efforts in the turnaround process. The overarching research question that guided this study was, what leadership practices do school leaders and district leaders believe are vital to the turnaround process?

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34

Akama, Yoko, e yoko akama@rmit edu au. "The Tao of Communication Design Practice: manifesting implicit values through human-centred design". RMIT University. Applied Communication, 2008. http://adt.lib.rmit.edu.au/adt/public/adt-VIT20080730.143340.

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Abstract (sommario):
This research explores how human values and concerns are manifested and negotiated through the process of design. In undertaking this study, a variety of design interventions were explored to facilitate how values can be articulated and discussed amongst project stakeholders during the design process. These design interventions will be referred to as projects within the exegesis. In this exegesis, I will argue for the importance of a dialogic process among project stakeholders in the creation of a human-centred design practice in communication design. This exegesis explains the central argument of the research and how the research questions were investigated. It presents a journey of the discoveries, learnings and knowledge gained through an inquiry of the research questions. The total submission for this research consists of the exegesis, exhibition and oral presentation. Through each mode of delivery I will share and illuminate how the research questions were investigated.
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35

Popa, Ana Sorina. "You become what you practice: application of Tai Chi principles to piano playing". Thesis, Boston University, 2012. https://hdl.handle.net/2144/12593.

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Abstract (sommario):
Thesis (D.M.A.)--Boston University PLEASE NOTE: Boston University Libraries did not receive an Authorization To Manage form for this thesis or dissertation. It is therefore not openly accessible, though it may be available by request. If you are the author or principal advisor of this work and would like to request open access for it, please contact us at open-help@bu.edu. Thank you.
This work explores the interface between Eastern philosophy, body mechanics, mental attitudes and breathing patterns found in the practice of Tai Chi Chuan, and the Western approach to piano playing. Through a thorough process of integration, the application of the principles learned in the practice of Tai Chi Chuan leads to an optimization of expression in piano playing and a clear path for rehabilitation from injury. Chapter 1 discusses the general philosophical, cultural and scientific environment in which the Western pianist develops. Chapter 2 shows that this environment gifts the pianist with a set of inherited assumptions which lead towards injury. Chapter 3 presents a summary of salient points about Chinese philosophy, art and medicine, and their embodiment in the martial art of Tai Chi Chuan. Chapter 4 discusses the application of Tai Chi principles to piano playing through training methods that include both static and moving postures, alone or during partner interactions; it also includes observations about breathing. The work concludes with a commentary on pedagogy and retraining.
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36

Du, Zhi-cang. "A fiscal impact model for Montgomery County : practicum in planning /". Master's thesis, This resource online, 1991. http://scholar.lib.vt.edu/theses/available/etd-01262010-020105/.

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37

Rademeyer, Conrad. "The impact of capital gains tax on estate planning : a practical decision making model for investing and estate planning". Thesis, Stellenbosch : Stellenbosch University, 2002. http://hdl.handle.net/10019.1/53122.

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Abstract (sommario):
Thesis (MBA)--Stellenbosch University, 2002.
ENGLISH ABSTRACT: After many years of speculation about the possible introduction of a capital gains tax in South Africa, the tax is finally with us. Coming on top of the move to a residence basis of taxation, the introduction of the capital gains tax will impose a massive burden on the limited, skilled administrative recourses available to taxpayers and the SARS alike. Amongst investors and even some professional financial advisors such as auditors and attorneys there still is confusion and not a lack of knowledge on CGT. Appropriate planning and structuring is seldom performed. The potential CGT liability escalates every year depending on the growth rate of the particular asset. CGT will therefor be an unavoidable and growing problem for investors. Planning for the CGT goes hand in hand with estate planning and requires decisions to be taken now. The purpose is to position and structure your portfolio to avoid or reduce future tax liability (CGT and estate duty). In this study an Excel program was developed in order to calculate CGT. The model (Estate Advisor) also has a decision function and can calculate and predict future CGT liability. The purpose of the model is to test the result of a range of decisions and assumptions quickly and accurately. This enables the investor to decide on entities and structures that would best suit his situation given the assets under his control. The Estate Advisor is a tool for producing different scenarios of future situations regarding CGT and estate duty. It helps the investor to investigate and consider different options regarding his investments with regard to CGT.
AFRIKAANSE OPSOMMING: Na baie jare van onsekerheid en gissings omtrent die moontlike implementering van Kapitaalwinsbelasting in Suid-Afrika, is hierdie belasting finaal geïmplementeer deur die SAID. Die implementering van KWB val saam met die verskuiwing na "verblyf' as "bron" van inkomstebelasting. Tesame sal dit groot druk uitoefen op die beperkte administratiewe bronne wat aan die belasingbetaler en die SAID beskikbaar is. Tussen gewone beleggers en selfs ook tussen sommige professionele finansiële adviseurs (ouditeure en prokureurs) heers daar in 'n groot mate onsekerheid en onkundigheid met betrekking tot KWB. Die probleem is dat 'n ferm basis van kennis van KWB benodig word om in staat te wees om die berekeninge te doen. 'n Gevolg van hierdie situasie is dat dringend benodigde aandag nie altyd aan beleggers geskenk word nie. Die potensiële KWB aanspreeklikheid eskaleer elke jaar met die betrokke groeikoers van die onderliggende bate. KWB is dus 'n onafwendbare en groeiende realiteit vir beleggers. Die beplanning vir toekomstige KWB gaan hand aan hand met beplanning vir boedelbelasting doeleindes. Die doel is om die belegger se portefeulje te posisioneer en struktureer sodat toekomstige belastingaanspreeklikheid (KWB en boedelbelasting) beperk kan word. In hierdie tesis is 'n eenvoudige Excel model ontwerp om KWB en boedelbelasting te bereken. Die model doen al die berekeninge en haal dus die las van die belegger af om oor detail kennis van KWB te beskik. Die model (Estate Advisor) het ook 'n besluitnemingsfunksie waar die belegger verskillende opsies kan oorweeg en toets. Die model word gebruik om toekomstige KWB te voorspel en bereken. Dit stel die belegger in staat om besluite te maak omtrent entiteite en strukture wat in sy situasie die gepaste antwoord sal wees. Die model moet nie gesien word as 'n instrument om beleggingsbesluite te neem nie en dit kan nie keuses uitoefen tussen verskillende beleggingsbates nie. Die doel van die model is uitsluitlik om die effek van verskillende besluite en aannames te vinnig en akkuraat te bereken. Dit dien as hulpmiddel vir die beplan van KWB en boedelbelasting wat in die toekoms betaal moet word. Die Estate Advisor is 'n instrument vir die produsering van verskillende scenarios van toekomstige situasies met betrekking tot KWB en boedelbelasting. Dit help die belegger om verskillende opsies te oorweeg en die beste beleggingsbesluit te maak.
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38

Courtelis, Christos Constantine. "An investigation of international environmental tax practices in selected countries". Thesis, 2013. http://hdl.handle.net/10210/8548.

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Abstract (sommario):
M.Comm. ( Accounting)
Globally, the temperature is rising and some of the consequences are starting to show. This effect is known as global warming. The issue of global warming and environmental pollution is more serious than people realise as it is the starting point of potentially catastrophic events to come. The implementation of global emission reductions is imperative in order to prevent further global warming. All countries should be actively involved in the prevention of further global warming and the reduction of pollution. With the use of a comparative analysis of various environmental taxes internationally, the countries with established environmental tax frameworks can be used as a basis for the development of effective environmental tax frameworks in developing countries. This will ensure that developed as well as developing countries will be held accountable for their emissions and hopefully will make efforts to reduce their emissions. South Africa has very few environmental tax policies and the existing acts are not sufficient to ensure the effective reduction and management of its emissions. Successful environmental tax policies are those that are economically viable and easy to implement. This is achieved through successful implementation by the tax authorities as well as the taxpayers’ cooperation and acknowledgement of these policies.
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39

"Cook County Land Bank and Land Bank Best Practices". Tulane University, 2013.

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40

CHANG, CHIN-NAN, e 張金男. "The Comparison Between Tax Dispute Administrative Remedy Practices Across Taiwan Strait". Thesis, 2001. http://ndltd.ncl.edu.tw/handle/79028415427293297371.

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Abstract (sommario):
碩士
中原大學
會計研究所
89
Tax Dispute Administrative Remedy System is one of the critical legal systems for a modem country. Behind its formation and development is a long history of evolution. The Tax Dispute Administrative Remedy System defined under the laws of Mainland China, and that of Taiwan are far different owing to difference in political, cultural and other areas, segregation in geographical area and information communications. Consequently tax-payers across Taiwan Strait are unlikely to be able to attain any timely administrative remedy for their own security while encountering the improper practice or actions of the tax authority or agencies. Further, they are affected by the fears and threats that affect their decision-making in operation and in investment strategies. The consequences will be rather destructive to the people and authorities across the straight. The advert outcomes are particularly unnecessary on the basis that not only the "3 Small Links" came into reality but also the "3 Big Links". The consensus of economic and trade exchanges across the straight is developed and nearly established and thus tax burden is unavoidable. So, how to seek remedy against the improper or even illegal taxation measures is now an issue demanding answers. This study first aims at the remedy systems available to the citizens when their rights/interests is infringed or endangered through the administrative procedures of the government authorities. During the course of this study, the statistical data and information officially published by the agencies across the strait are collected, and then they are analyzed and interpreted in depth according to practical situations. Special efforts are given to the jurisprudence and practice of the related laws and regulations. While it is impractical to conduct a complete and comprehensive study because of the vast area in Mainland China, it is still practical for this study to achieve the purpose and objectives by taking the related papers and works of the leading scholars, articles on journals etc. available in the open market through collecting, reading, referencing and taking examples, so as to analyze and conclude the laws, codes, and the implementation of the systems and to find out the advantages and disadvantages the derive. In this study, the Tax Dispute Administrative Remedy System in Taiwan is found encompassing the following processes : Re-examination ® Petition ® First Trial for Administrative Litigation ® Second Trial for Administrative Litigation; while the same in Mainland China if found encompassing the phases as follows: Appeal for Re-examination ® Petition ® First Trial for Administrative Litigation at People''s Court ® Second Trial for Administrative Litigation at People''s Court. Next, this study investigates into the implementation of the remedy at each phase one after another, taking individual cases as examples, and presents proposals to the entities as follows for reference.
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41

HUANG, WAN-TING, e 黃婉婷. "A Tax Issue Study on the Income Tax Practices of Non-profit Organizations ─ Centering on Juridical Persons in Medical Care". Thesis, 2017. http://ndltd.ncl.edu.tw/handle/ve2xwr.

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Abstract (sommario):
碩士
國立臺北大學
法律學系一般生組
105
Non-profit organizations play important roles in our society today, but some of them are reduced to tax havens both in Taiwan and PRC (Mainland China, exclusive of Hong Kong and Macau, hereinafter referred to as ”China”), contrary to tax equity and tax neutrality principles. To protect the rights of taxpayers and to meet the equal burden of tax, the practice of tax preference should not only have the legal provisions in formal construction but should also have substantive justification. Therefore, the strength of the disclosure of information of non-profit organizations that enjoy tax preference should be regulated by law. This paper is mainly based on the related tax laws and regulations for non-profit organizations of Taiwan and of China, as well as the related books, journals, papers and seminars of reference materials, to observe and analyze the views of the court on the relevant issues. Discussing and exploring its advantages, disadvantages and the difference of the income tax practices of non-profit organizations between Taiwan and China, and then complemented by the current situation and problems in Japan, to make recommendations and to provide the reference for future amendments of Taiwan and of China. In general, we should clearly define the legal status of non-profit organizations (especially "non-profit hospitals"), whether in Taiwan or in China — in particular their status in tax law, and should raise the level of taxation legislation on non-profit organizations and pay attention to its connection with the enabling statute and other laws, avoiding exceeding the enabling statute or conflicting with other laws. Besides, we should separate the set-up qualifications of non-profit organizations from the tax preference qualifications of non-profit organizations. When we amend the law in the future, we could take the system of “specific juridical persons in medical care” in Japan into consideration, or it’s also a way to transform non-profit organizations into "social enterprise" or "public trust." The purpose of the study was to clarify the status of non-profit organizations in the legal framework, to help non-profit organizations better understand how to get the qualification of tax preference and how to deal with tax issues, and to review the shortcomings of the current legal system at the same time. Furthermore, by discussing the dilemma and the current situation faced by the non-profit organizations, the cases of the court, and the tax system in Japan, it’s expected to have a better solution for non-profit organizations and to protect taxpayers' rights more properly.
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42

Keulder, Carika. "Does the constitution protect taxpayers against the mighty SARS? – An inquiry into the constitutionality of selected tax practices and procedures". Diss., 2012. http://hdl.handle.net/2263/27775.

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This dissertation purports to ascertain whether the Constitution of South Africa provides protection for taxpayers against specific practices and procedures utilised by SARS in order to collect taxes. The collection of taxes is imperative in ensuring that economical and socioeconomical objectives of the government are met. SARS is therefore awarded specific powers to achieve this. On the other side are taxpayers who are awarded constitutionally enshrined rights. Said rights may only be limited if the limitation is reasonable and just. Tension between SARS’ task and the taxpayers’ rights exist. This dissertation endeavours to find a balance where SARS can effectively collect tax whilst the taxpayers’ rights are not unreasonably and unjustly limited. The Constitution affords taxpayers the right to just administrative action. The right entails, amongst others, that when a dispute arises both parties sides must be heard. The right to just administrative action also includes legitimate expectations. A practice has transpired where SARS denies being bound by its own rulings and notes. A legitimate expectation is, nevertheless, created that SARS will act in accordance with its rulings and notes. The doctrine of legitimate expectations will provide assistance to the taxpayer in this situation. SARS further has the power to appoint a taxpayer’s agent. This procedure does not provide for the taxpayer to state his case before such an appointment is made. This prima facie violates a person’s right to just administrative action. When compared to the civil procedure of garnishee orders valuable differences transpired which will assist in elevating the tension between the taxpayer’s rights and SARS’ duty. A further right afforded, is the right of access to the court. The statement procedure and the “pay now, argue later” rule appear to be in conflict with said right. The statement procedure, which empowers SARS to file a statement at court to be made a judgment, exceeds the normal recourse available for ordinary litigants, namely the default judgment procedure. This procedure has, however, survived constitutional scrutiny. The “pay now, argue later” rule entails that a taxpayer must first pay the assessed amount before questioning the amount. This procedure is a departure from the general rule utilised in civil proceedings. It was held that this procedure is constitutional. This is, however, questioned due to the fact that at the time this rule is invoked the court’s jurisdiction is excluded. Furthermore, a taxpayer can rely on his right to property. If SARS unreasonably delays a refund due to the taxpayer this will violate said right. The situation relating to money owed in civil matters and the judgment of Sage Life Ltd indicates that a taxpayer will be entitled to interest and accordingly the violation will not be unreasonable or unjust. Moreover a taxpayer is afforded the right to privacy. Tension may arise when SARS obtains a warrant to search and seize the taxpayer’s property. This procedure is similar to the procedure of obtaining a warrant in terms of the Criminal Procedure Act. Declaring this procedure unconstitutional is implausible. Other countries faced with the tension between their revenue service collecting tax and their taxpayers’ rights, are utilising certain measures to reduce this tension. Amongst other a service charter, to provide legal certainty, instituting complaints forums, to deal with poor service, and providing brochures, to educate the taxpayers is identified. The predominant measure is, however, the office of the ombudsman. The Constitution, together with other measures, does provide adequate protection for a taxpayer against SARS. Accordingly, the tension between SARS’ duty and the taxpayers’ rights is balanced with the assistance of the Constitution. Copyright
Dissertation (LLM)--University of Pretoria, 2012.
Mercantile Law
unrestricted
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43

Samkin, James Grant. "South African deferred tax practices within the context of positive and normative accounting theories". Thesis, 1993. http://hdl.handle.net/10413/7804.

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Abstract (sommario):
The primary purpose of this study is to establish whether, by examining the responses to various pronouncements covering deferred taxation, a comprehensive theory of accounting can be said to exist in South Africa. Four case studies were conducted on the responses to the various pronouncements issued by the Accounting Practices Committee on deferred tax. The respondents to these pronouncements were surveyed to establish their perception and understanding of various aspects of accounting theory, deferred taxation and corporate management's influence on the accounting standard setting process. The results of the study indicate that, although the recognition of a positive theory of accounting cannot be conclusively shown to exist, certain of the factors that can be said to drive the accounting standard setting process are identified. A positive relationship is perceived to exist between the accounting standard setting process and management compensation.
Thesis (M.Com.)-University of Durban-Westville, 1993.
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44

Tsai, Wen-Te, e 蔡文德. "A Study of National Tax Service Failure and Service Recovery Practices-Taking National Tax Administrations in Taoyuan County Area as Examples". Thesis, 2004. http://ndltd.ncl.edu.tw/handle/13895362499278591521.

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Abstract (sommario):
碩士
東吳大學
企業管理學系
92
Abstract The service industry is obviously the main stream of the modern industries. To enhance the competitive ability, the service industry has to continuously maintain the original customers and strive for new customers. Because customers are critical to enterprises, without the customers, the lives of the enterprises will terminate. Therefore, the thinking of “Customer Orientation” is unavoidable for enterprises operation. Actually, the thinking of “Customer Orientation” is not only required for enterprises operation, it is also required for the largest service institute, the government, to build the “Customer Orientation” method of work. ( Y.C.Lin, 2003) According to the research of the enterprises service of scholars, “ Service Failures” always exists in the service industry. Therefore, “ Service Recovery” plays an important role in the service industry. As far as “ Service Failures” and “ Service Recovery” are concerned to the taxes service work, due to the reasons as follow, they play important roles. 1. “ Taxes Service Failures” is highly related to the fiscal revenues of the country. 2. The unfavorable affect of “ Taxes Service Failures” is severer than other administrative works 3. If the practice of taxes service recovery were appropriately executed, it would be helpful to maintain the fine relationship between the tax bureaus and the taxpayers. However, most of the domestic documents concerning “ Service Failures” and “ Service Recovery” focus on the researches of private sectors. There are few documents related to the public sectors. The range of the research of the public sector is broad, so this research chose to target on the studying of the two issues of the national taxes service in order to complement the knowledge of this field. This research adopted CIT, (Critical Incident Technique). After processing the analysis of 115 open questionnaires to the taxpayers of the Taoyuan region of National Tax Administration of Northern Taiwan Province, Ministry of Finance, we classified the taxes service failures into two major categories, which include six sub-categories. The first major category is about the service failure of the aspect of procedures. We sort it into three sub-categories, “ the service failure of contacting”, “ the service failure of processing”, and “ the service failure of the system”. The second major category is about the service failure of the aspect of substantiation. We sort it into three sub-categories, “ the arguments of the auditing content”, “the errors of the auditing content”, and “ the unreasonable part of the tax system”. Ⅲ Between the two major categories of the service failures, the probabilities of the failures of the first category, the service of the procedures, is higher. When the service already happened, the probabilities for the taxpayers to express the complaints are higher for the second category, the service of the substantiation. The ratio of the second category is 2.6 times of the first category. After further analyzing, this research found out that the reasons to cause the service failures of the aspect of procedures are as follow, 1. The problem of the individual service concept and attitude. 2. The problem of management, system, and the operation design. 3. The shortage of the manpower of the levy work. 4. The problem of the professional abilities. 5. Other problems. In addition, the reasons to cause the service failures of the aspect of substantiation are as follow, 1. The insufficiency of trainings, the professional abilities, and the legal recognition. 2. The problem of the personal subjective and selfish departmentalism attitude. 3. The problem of artificial ignorance and mistakes. 4. The problem of heavy workload and insufficiency human resources. 5. Other problems. Based on the open questionnaires and the visits with the elites, we found out that the channel and the recovery approaches of the tax service are diversified and smooth. As to the measures of service recoveries to exercise influence over the fairness recognition and the timing effects, it shows that the ratio of the satisfaction of the outcome fairness is higher than the satisfaction ratios of the procedural fairness, interaction fairness, and the timing effect. Finally, based on the results of the analysis of the research, we offer several suggestions to the national tax distractions and the future researchers. Keywords:Service Failures, Service Recovery, Critical Incident Technique( CIT)
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45

Hsu, Yung-Yi, e 許永議. "A Research on the Income Tax Practices of Non-profit Organization in Taiwan". Thesis, 1998. http://ndltd.ncl.edu.tw/handle/05048932631978262670.

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Abstract (sommario):
碩士
淡江大學
會計學系
86
The Non-Profit Organization (NPO) is also called the third sector or the independent sector. They exist everywhere of our daily life. The service they offered promotes civilization evolution and development directly or indirectly, and provides important contribution to society. Most countries consent tax exemption or preferred treatment to NPO in the standpoint of encourage private sector to conduct public welfare affair, so as in Taiwan.   The Ministry of Finance of Taiwan modified the Tax Exemption Criteria in 1994 and levied income tax on the sales of goods or services of NPO. Its purpose is to prevent NPO to use the name of public welfare but factually pursuing profit. After the modification, some NPO rejected to file income tax returns and opposed the tax because they worried they may lose their tax preference. Though it induced extensive discussions, some essential problems still remain, such as to what extent it increases the tax burden on NPO, will it influence their business operation, and the shortcoming of the new criteria, etc. All these income tax issues will discuss in this thesis. The study covers theoretic analysis, international comparison, secondary information and ques tionnaire survey. Some problems and recommendations have been presented.   The main findings of this research are: Although Taiwan government levied income tax on NPO after 1995, which were levied under the reason conducting commercial activities and been levied income tax is as low as 1.6% of all NPOs. The reasons is tax authority mostly issuing some loosen interpretations in order to avoid controversies and opposition, such as whether the capital expenditure been deducted as the expense at the year of payment or depreciation is decided by the NPO itself. The method to allocate costs and expenses between to public welfare and commercial activity is chosen by the NPOs. To most NPOs, the influence is not as severe as predicted, but many managers afraid of losing the tax preference. From the questionnaire survey, the following results are obtained:   1.Most people support government to levy tax on NPO''s commercial activities.   2.The minimum restriction of 80% expenditure to revenue is highly satisfied.   3.The scope of commercial activities should be lessen, especially for those organizations with higher public welfare tendency.   4.To set a specify regulation for NPO is in important to cope with practical needs.
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46

Griswold, Jerry Robert. "Conservation credit motivating landowners to implement soil conservation practices through property tax credit /". 1989. http://catalog.hathitrust.org/api/volumes/oclc/20306023.html.

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Thesis (Ph. D.)--University of Wisconsin--Madison, 1989.
Typescript. Vita. eContent provider-neutral record in process. Description based on print version record. Includes bibliographical references (leaves 147-159).
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47

Cheng, Chih-Chih, e 鄭芝智. "The Related Research of Individual Income Tax Investigation on Income from Executing Professional Practices". Thesis, 2015. http://ndltd.ncl.edu.tw/handle/5jcdu6.

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Abstract (sommario):
碩士
中華大學
企業管理學系碩士班
103
For past years, Individual Income Tax is a major proportion of total national tax revenues. Individual Income Tax is declared by taxpayer’s self-report in our country, it has advantages such as it can achieve the principle of taxpayer’s taxability and social wealth equality. However, it has also disadvantages such as it needs many arrangements in different agencies because of tediously tax collection and high taxation cost. Low honesty is observed in professional practician’s tax declaration. Therefore, it’s very important task for tax authority to truly control sources of tax revenues, to carry out complete taxation procedures and to effectively exert professional income audit skills. The audit staffs must understand the present taxation system, tax laws and having professional audit skills so that they can use new audit technology innovations and effectively use tax laws. By doing this, huge tax loss due to tax aversion can be prevented. In this study, I focus on tax audit practices, audited cases selecting system, unsuitable tax laws, system of rewards and penalties, and auditing toward private hospitals’ .medical cosmetology and dental implants. I purpose some recommendations which can be used to improve tax-collection skills and to review untimely laws and collection skills. I hope the recommendations can apply to develop a more comprehensive taxation system and to thwart business operators’ opportunistic behaviors. I also hope that business operators can make more efforts to understand related tax laws and to establish a complete and healthy accounting system so that accounting records are correctly reliable. After that, I think both business operators and the tax authority win together.
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48

Chan, An-nan, e 陳安男. "A Study for How to Improve Tax Accounting Practices in Small and Medium Enterprises (SME)". Thesis, 2011. http://ndltd.ncl.edu.tw/handle/26109152679422056825.

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Abstract (sommario):
碩士
朝陽科技大學
企業管理系碩士班
99
According to the census issued in December 2009, by the Small and Medium Enterprise Administration, Ministry of Economy Affairs, the small to mid-size companies currently account for 97.91 percent of the total number of business entities in Taiwan. These companies have small business structures and less capital investments. They usually lack a sound accounting system. Business administrators are deliberately on the lookout for the marketing strategy and also the research and development of a new product. Accounting and Finance are two areas that are often overlooked. Particularly out of ignorance of Tax Accounting in income tax and sales tax causes most business owners to pay more taxes than they are obligated without knowing it. Furthermore, in the event of failing to comply with tax laws, companies are imposed with large fines and penalties that create significant business loss. In view of risk management in taxation being an important issue of business administration, the purpose of this paper will be examining problems on tax accounting practices from the small and medium enterprise’s perspective and to provide a practical guidance to their business managers. The analysis is focused in seven categories based on the difference of their natures: (1) Business Revenue (2) Cost of Goods Sold (3) Operating Expenses (4) Non-Operating Revenue and Losses (5) Balance Sheet Accounts (6) Income Tax Withholdings (7) Administrative Relief. It is my hope that this paper will awake the business administrators and accounting staff of the small and medium enterprises to face the challenge of tax accounting; to understand tax regulations; to strengthen their ability in tax accounting practices and, eventually to minimize the risk of tax management and promote the efficiency of business operation
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49

Kuo, Chung-Ming, e 郭宗銘. "A Study on The Practices of Wealth Management and Tax Planning in A Trust Perspective". Thesis, 2004. http://ndltd.ncl.edu.tw/handle/64462246261376658651.

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Abstract (sommario):
碩士
國立臺灣大學
會計學研究所
92
Graduate Institute of Accounting National Taiwan University Name : Kuo, Tsung-Ming Adviser : Lin, Suming, Ph.D., CPA Title : A Study on The Practices of Wealth Management and Tax Planning in A Trust Perspective Month/ Year : June, 2004 Since the enactment of Law of Trust, Law of Trust Industry Act, and other related Tax Laws, it is believed that Taiwan’s regulatory environment regarding trust businesses has been established at the preliminary stage. However, it appears that the general public has not yet fully comprehended the fundamental and social functions of a trust, resulting in discouraged development of recent trust businesses. Furthermore, the government has not provided specific measures or a set of fair rules on operation of trust businesses. The purpose of this thesis is to examine and analyze the practices of wealth management and tax planning in a trust perspective. The current Taiwan trust system operates and aims at achieving the following goals, including the use of trust to achieve wealth management, the use of trust to resolve gifts/estates issues, the use of charitable trust to resolve relevant issues of corporate juridical persons, the use of trust to achieve better tax planning, the use of employee stock ownership trust to create value-added activities for both employees and company, the use of employee stock bonus ownership trust to retain talents and motivate employees, the use of life insurance trust to take care of specific persons, the use of trust to assure the custody of properties, and the use of trust to resolve the wealth management issues on employees of public services. This thesis probes into the practices of trust, including the planning of holding huge amounts of real estates, the planning of family stock holding, the planning of stock holding of technical team, and the planning for engaging in charitable businesses. This thesis analyzes background information, potential issues, and factors for consideration of four cases and ultimately proposes concrete suggestions. Taiwan’s trust practice is still in the early stage and regulations and principles are not complete. This research discusses relevant practical trust issues and consults with experts in the trust industry. Hopefully this research would benefit the future of trust operations. Keywords: Trust、Wealth Management、Tax Planning
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Chen, Yen-Jen, e 陳衍任. "A Study on Borrowing License Practices in the Construction Industry and the Violation of it on Business Tax". Thesis, 2006. http://ndltd.ncl.edu.tw/handle/37779347425146640893.

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