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Dissertation
L'avantage fiscal des holdings luxembourgeoises au niveau de la planification successorale des habitants du Royaume de Belgique
Authors: --- --- ---
Year: 2017 Publisher: Liège Université de Liège (ULiège)

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Abstract

Over the years, the succession planning has raised a real fascination in the mind of the taxpayers. The paramount of this art is to be able to combine in a unique tool both the active management - maintaining a certain control and a regular income - and the succession according to the taxpayer's needs. The aim is to allow the optimized transfer of goods at the time of the deceased’s death. 
A large number of Belgian residents are obsessed with the idea that a small part of the population referred as the High Net Worth Individuals, may use different holding structures to evade or to reduce their tax burden. They morally condemn the use of this estate planning by the H.N.W.I. even if it is not illegal in facts. 
The purpose of this thesis is to study if the use of the Grand Duchy of Luxembourg’s holding companies such as the SO.PAR.FI. and the S.I.Ca.V.-S.I.F. still offers “a tax optimization with regards to the Belgians’ succession planning?”. This will be achieved through an in-depth analysis of the SO.PAR.FI. which is fully eligible to the Double Taxation Agreements and which is fully subject to Luxembourg’s corporate tax and minimum wealth tax. In addition, it will be demonstrated why the attractiveness of the S.I.Ca.V.-S.I.F. is now reduced despite the unique levy of a limited annual tax. In fact, due to its portfolio risk aversion and diversification constraints as well as the recent evolution of the Belgian legislation, this holding structure will be useless in achieving the Belgian paterfamilias’ objective of tax optimization. 
In addition, this paper will study the benefits for a Belgian resident to move to the Grand Duchy of Luxembourg: the step-up principle and the 0% rate of succession rights in direct line.


Book
Taxing the rich : a history of fiscal fairness in the United States and Europe
Authors: --- ---
ISBN: 1400880378 Year: 2016 Publisher: Princeton, NJ : Princeton University Press,

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In today's social climate of acknowledged and growing inequality, why are there not greater efforts to tax the rich? In this wide-ranging and provocative book, Kenneth Scheve and David Stasavage ask when and why countries tax their wealthiest citizens-and their answers may surprise you.Taxing the Rich draws on unparalleled evidence from twenty countries over the last two centuries to provide the broadest and most in-depth history of progressive taxation available. Scheve and Stasavage explore the intellectual and political debates surrounding the taxation of the wealthy while also providing the most detailed examination to date of when taxes have been levied against the rich and when they haven't. Fairness in debates about taxing the rich has depended on different views of what it means to treat people as equals and whether taxing the rich advances or undermines this norm. Scheve and Stasavage argue that governments don't tax the rich just because inequality is high or rising-they do it when people believe that such taxes compensate for the state unfairly privileging the wealthy. Progressive taxation saw its heyday in the twentieth century, when compensatory arguments for taxing the rich focused on unequal sacrifice in mass warfare. Today, as technology gives rise to wars of more limited mobilization, such arguments are no longer persuasive.Taxing the Rich shows how the future of tax reform will depend on whether political and economic conditions allow for new compensatory arguments to be made.

Keywords

Imposte sul reddito --- Wealth --- Wealth --- Income tax --- Income tax --- Rich people --- Rich people --- History. --- History. --- History. --- History. --- Taxation --- History. --- Taxation --- History. --- Europa. --- USA. --- United States. --- Europe. --- Ability To Pay. --- At Best. --- Bond (finance). --- Capital levy. --- Conscription. --- Consideration. --- Consumption tax. --- Corporate tax. --- Debt. --- Direct tax. --- Economic efficiency. --- Economic growth. --- Economic inequality. --- Economic interventionism. --- Economic policy. --- Economics. --- Economist. --- Economy. --- Emmanuel Saez. --- Employment. --- Equality of outcome. --- Estate tax in the United States. --- Excise Tax. --- Expense. --- Finance. --- Financial crisis. --- Flat tax. --- Funding. --- Gift tax. --- Globalization. --- Government revenue. --- Gross domestic product. --- Incentive. --- Income distribution. --- Income tax in the United States. --- Income tax. --- Income. --- Indirect tax. --- Inflation. --- Inheritance tax. --- Institution. --- Jean Tirole. --- John Stuart Mill. --- Legislation. --- Legislature. --- Luxury goods. --- Mass mobilization. --- Middle class. --- Oligarchy. --- On War. --- Payroll tax. --- Pension. --- People's Budget. --- Percentage point. --- Percentage. --- Political economy. --- Political party. --- Political science. --- Political spectrum. --- Politics. --- Progressive tax. --- Property tax. --- Provision (accounting). --- Public finance. --- Quarterly Journal of Economics. --- Rates (tax). --- Redistribution of income and wealth. --- Sacrifice. --- Salary. --- Self-interest. --- Stanford University. --- Suffrage. --- Tariff. --- Tax Fairness. --- Tax Schedule. --- Tax deduction. --- Tax incidence. --- Tax law. --- Tax policy. --- Tax rate. --- Tax revenue. --- Tax. --- Taxation in the United Kingdom. --- Taxation in the United States. --- Taxpayer. --- Technology. --- Thomas Piketty. --- Total revenue. --- Universal suffrage. --- University of Amsterdam. --- War effort. --- War reparations. --- War. --- Warfare. --- Wealth tax. --- Wealth. --- Welfare state. --- Welfare. --- World War I. --- World War II.

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