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Posted by / 09-Dec-2016 02:42

Tax consequences of liquidating

ARM'S LENGTH TRANSACTION -- A transaction among parties, each of whom acts in his or her own best interest.

ASSESSMENT -- Act of computing the tax due ASSOCIATED ENTERPRISES -- Generally speaking, enterprises are associated where the same persons participate directly or independently in the management, control or capital of both enterprises, i.e. ATTRIBUTION RULES -- Rules that create ownership by attributing stock to one party even though the shares are legally owned by another party; often called constructive ownership of stock.

The decisive criterion is whether the activity of the fixed place of business in itself forms an essential and significant part of the activity of the enterprise as a whole.

AUXILIARY COMPANY -- Company which is part of a group of companies and which supplies auxiliary services to group companies.

AVOIDANCE -- A term that is difficult to define but which is generally used to describe the arrangement of a taxpayer's affairs that is intended to reduce his tax liability and that although the arrangement could be strictly legal it is usually in contradiction with the intent of the law it purports to follow. evasion -B- BACK-TO-BACK LOAN -- Method of borrowing between related parties where a loan is channelled through an independent third-party intermediary. Bad debts may usually be treated as losses and written off against a reserve for such debts.

BALANCE SHEET -- Statement of the financial position of a business as of a particular date.

The tax embodied in the price paid for the assets may be credited to the trader over a period of years corresponding to the life of the assets.

APA -- See: Advance Pricing Arrangement APPORTIONMENT METHOD -- One of the methods used to allocate income and expenses between related enterprises using a formula consisted of some factors such as sales, property, or payroll.

AGENCY -- A business that provides a particular service to a company (that are outside of the country where the agency is located).Disclaimer: Explanations on the terms are very condensed and may not be complete.They are not considered to necessarily reflect official position of the OECD in interpreting international tax terms, for example, in the tax treaty context.ALIEN, TAX TREATMENT OF -- A person who is not a citizen of the country in which he or she lives.In general, most countries do not distinguish between nationals and aliens for tax purposes; rather tax liability is based on residence and/or domicile.

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AUDIT -- Examination and verification carried out by an outside agency (such as an accountancy firm or the tax authorities) of a taxpayer’s books and accountants and/or the general accuracy of returns and declarations, either as a routine operation, or where evasion is suspected.

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