FINANCE

US TAX SYSTEM

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US tax system tax its citizen’s global income irrespective of the place of resident although allowance is given for certain level of income earned abroad.

TAXES IN US

1.Income taxes-Personal and Corporate taxes
2.Property taxes
3.Estate/Inheritance taxes.
4.health insurance.
5.Gift taxes
6.Capital gain taxes
7.Sales tax

8.Payroll taxes
9.medicare taxes

10.Others (yet to be updated)

Summary of U.S. Corporate Taxes:In the United States, corporations are subject to a range of taxes, including federal, state, and sometimes local taxes. Here’s an overview of the key components of U.S. corporate taxation:

1. Federal Corporate Income Tax

Tax Rate: The U.S. has a flat federal corporate income tax rate of 21% (as of 2024). This rate applies to all corporate income above the threshold of tax-free income.Taxable Income: Corporate income is calculated after deductions, including business expenses, depreciation, interest payments, and compensation.Alternative Minimum Tax (AMT): The corporate AMT was repealed under the Tax Cuts and Jobs Act (TCJA) in 2017, so corporations are no longer subject to this additional tax.

2. State Corporate Taxes

Each state in the U.S. has its own corporate tax system, with varying rates. State corporate tax rates typically range from 1% to 12% of taxable income.Some states, such as Nevada, South Dakota, and Wyoming, have no corporate income tax.States may also impose additional taxes on gross receipts or sales.

3. Tax Deductions and Credits

Deductions: Corporations can reduce their taxable income through deductions for ordinary business expenses such as salaries, operating costs, R&D, and depreciation.Credits: There are several tax credits available to corporations, including credits for research and development (R&D), renewable energy investments, and foreign tax credits to avoid double taxation.

4. International Taxation (Global Tax System)

Controlled Foreign Corporations (CFCs): U.S. multinational companies are taxed on their worldwide income, though they may defer taxes on foreign income until it is repatriated.Tax Reform (TCJA): The 2017 Tax Cuts and Jobs Act introduced provisions like the Global Intangible Low-Taxed Income (GILTI) tax and the Foreign-Derived Intangible Income (FDII) tax benefit, which aimed to reduce incentives to move profits overseas.Base Erosion and Anti-Abuse Tax (BEAT): Aimed at preventing large corporations from shifting profits out of the U.S., this tax imposes a minimum tax on certain payments made by U.S. corporations to foreign affiliates.

5. Other Taxes

Payroll Taxes: Corporations must pay Social Security, Medicare, and unemployment taxes on employee wages.Sales and Use Taxes: Corporations are also subject to sales tax in many states on the sale of goods and services. Some states impose use taxes on goods purchased outside the state but used within it.Excise Taxes: Certain industries, such as fuel, tobacco, and alcohol, face federal excise taxes.

6. Tax Filing and Reporting

Corporations must file an annual tax return (Form 1120) with the IRS. Large corporations may also be required to submit additional forms, such as Form 5471 for international activities.Corporations may also be subject to audit by the IRS or state tax authorities, particularly if they have complex financial structures or international operations.

7. Tax Avoidance and Planning

Many corporations engage in tax planning strategies to minimize their tax burden. This can involve structuring transactions, financing, and international operations in a tax-efficient manner.Transfer Pricing rules require multinational corporations to price intercompany transactions in a way that reflects market conditions, and they must be able to document these pricing decisions.

8. Recent Developments and Reforms

The Tax Cuts and Jobs Act (TCJA) of 2017 made significant changes to corporate taxation, including lowering the corporate tax rate from 35% to 21%, introducing a territorial system for taxing foreign income, and limiting certain deductions.Infrastructure Investment and Jobs Act (2021) and other recent proposals may affect specific industries or corporate behavior, particularly around green energy and infrastructure.

9. Dividends and Distributions

When a corporation distributes dividends to its shareholders, those dividends are generally subject to tax at the individual level under the preferential rates for qualified dividends.Corporations may also be subject to double taxation, where both the corporation’s earnings are taxed and shareholders are taxed on dividends.

10. Tax Planning Considerations

Summary of Capital Allowance in U.S. Taxes

Corporate tax planning often involves managing profits and deductions across multiple jurisdictions to minimize total taxes. For example, utilizing tax credits, restructuring operations, or engaging in mergers and acquisitions to optimize the tax position.In conclusion, U.S. corporate taxes are complex, with several layers of federal, state, and international taxes. Corporations can benefit from tax credits, deductions, and careful planning to manage their tax liabilities, but they must also comply with a robust system of reporting and regulations.

In the United States, capital allowances refer to tax deductions businesses can take for the depreciation of capital assets over time. These assets, typically fixed assets like machinery, equipment, buildings, and vehicles, lose value due to wear and tear, obsolescence, or age. The tax code allows businesses to recover the costs of these capital investments through depreciation deductions.

Here’s an overview of how capital allowances work in the U.S. tax system:

1. Depreciation of Capital Assets

  • Definition: Depreciation is a tax deduction that allows businesses to recover the cost of an asset over its useful life.
  • IRS Depreciation Methods: The IRS allows businesses to use specific depreciation methods to allocate the cost of an asset over time. The two primary methods are:
    • Straight-Line Depreciation: This method spreads the cost evenly over the asset’s useful life.
    • Accelerated Depreciation: This allows businesses to take larger deductions in the earlier years of the asset’s useful life. The Modified Accelerated Cost Recovery System (MACRS) is the most commonly used method.

2. MACRS (Modified Accelerated Cost Recovery System)

  • Purpose: MACRS is the primary system for calculating depreciation for tax purposes in the U.S.
  • Asset Classes and Recovery Periods:
    • Under MACRS, assets are categorized into different classes based on their type and expected useful life. Common categories include:
      • 5-year property: Equipment, computers, vehicles.
      • 7-year property: Office furniture, fixtures.
      • 27.5-year property: Residential rental property.
      • 39-year property: Non-residential real estate.
  • Depreciation Methods under MACRS:
    • General Depreciation System (GDS): This method allows businesses to take larger depreciation deductions in the early years of the asset’s life.
    • Alternative Depreciation System (ADS): This is a more conservative system that requires longer depreciation periods and slower deductions. It is generally used for certain types of property (e.g., tax-exempt property, foreign property).

3. Bonus Depreciation

  • Bonus Depreciation: The Tax Cuts and Jobs Act (TCJA) of 2017 introduced 100% bonus depreciation for qualifying property. Under this provision, businesses can immediately deduct the entire cost of certain new and used property in the year the property is placed in service, rather than depreciating it over multiple years.
  • Qualifying Property for Bonus Depreciation:
    • Property with a recovery period of 20 years or less (e.g., machinery, equipment, furniture).
    • Used property is also eligible for bonus depreciation, as long as it wasn’t previously used by the taxpayer claiming the deduction.
  • Phase-Out: The 100% bonus depreciation rate is set to phase down after 2022, reducing to 80% in 2023, 60% in 2024, 40% in 2025, and 20% in 2026.

4. Section 179 Expensing

  • Section 179 Deduction: This provision allows businesses to expense the cost of certain capital assets in the year they are purchased, rather than depreciating them over time.
  • Qualifying Property: Section 179 applies to most tangible personal property, such as machinery, equipment, and vehicles, as well as software.
  • Deduction Limitations:
    • For 2024, businesses can expense up to $1,160,000 of qualified property in a given tax year, subject to a phase-out threshold of $2,890,000 (if total purchases exceed this amount, the deduction is reduced dollar-for-dollar).
  • State Variability: Some states do not conform to the federal Section 179 limits or have different expensing thresholds.

5. Qualified Improvement Property (QIP)

  • QIP: Improvements made to the interior of non-residential real property, such as renovations to offices or retail spaces, can be eligible for bonus depreciation under certain conditions.
  • Tax Reform Impact: The TCJA made a provision for immediate expensing of QIP under bonus depreciation, which was a significant tax benefit for businesses making qualifying improvements.

6. Other Considerations for Capital Allowances

  • Mixed-Use Property: If an asset is used for both business and personal purposes, only the business portion can be depreciated.
  • Section 179 vs. MACRS: While both Section 179 and MACRS can apply to the same asset, businesses need to consider which option provides the best tax benefit based on their purchasing and income levels.
  • Alternative Minimum Tax (AMT): While bonus depreciation and Section 179 deductions can provide immediate tax relief, they may also affect AMT liability for certain businesses, as these deductions can reduce the alternative minimum tax base.

7. Impact of Capital Allowances on Business Taxes

  • Cash Flow Benefit: By reducing taxable income through depreciation, businesses lower their current-year tax liability, which increases available cash flow for reinvestment.
  • Long-Term Planning: While immediate expensing options like Section 179 and bonus depreciation provide significant short-term tax benefits, they can reduce deductions in future years, as the asset will not be depreciated over its full useful life.

Conclusion

Capital allowances in the U.S. tax system are designed to help businesses recover the cost of capital investments over time, with provisions like MACRS depreciationbonus depreciation, and Section 179 expensing offering flexibility in how and when businesses can claim deductions. These allowances provide significant opportunities for tax relief, but businesses must carefully navigate the different methods and limits based on the type of property and their financial situation.

DISCLAIMER: The above articles could contain error; please consult your tax consultant for advice.

We disclaim all liability arising from reliance on this article

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