미국에서의 연결납세 이론과 제도

Abstract

This article tried to analyse the basic strcture of that system while considering the historical development of the U.S. consolidated tax return system. The results are summarized as follows. At first, the current consolidated return regulations can trace their origin to 1966, but the rules that have been amended, revised, and clarified so many times since their original promulgation that many would argue that not much remains of 1966 regulations. At second, the current consolidated tax return system regards a business group which presumed his economic unity, and calculate the taxable income of group, and finally functions as tax system for the confirm of tax liability. At third, it is said to be a great feature in the U.S. tax system that to prevent tax avoidance schemes and rules for the calculation of consolidated taxable income had much effect on the structure connecting the viscosity. In this sense, the U.S. consolidated tax return system of any of the economic importance of the corporate group by the rationalization of taxation and the prevention of tax avoidance that the practical tasks, in some cases, superior to that made on the two axes can be understood. Corporate tax system equipped with the basic philosophy and logical coherence of regulation, as well as the prevention of tax avoidance and tax revenues that can not break from the practical tasks. However, the prevention of tax avoidance and tax revenues due to the strategic consideration of the original image is likely to distort the calculation of taxable income. Consolidated tax payment system in Korea is no exception on this point is not considered necessary to review.