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Corporations are granted the legal status of people. 依法建立的法人组织
This means that they can own property and borrow money.

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Corporate Ownership法人所有权
Corporations are owned by shareholders. Each share entitles its holder to a fraction of the




The Tax Base: Measuring Business Income税基：计算营业所得



Using the comprehensive definition of income, business income is receipts + net capital gains income – labor, interest, material, and other business costs. 营业所得+净资本利得-营业成本（劳动成本、利 息支付、其他营业成本）=净应税所得 In the U.S., only realized capital gains are included in net taxable income for corporations. 在美国，只有已实现的资本利得包括在公司的应 税收入内。
dividends
declared, votes at shareholders’ meetings that determine the operations of the corporation, and proceeds if the corporation were to dissolve.

Others counter that because payment on corporate debt (interest) is deductible to the corporation but payment on equity (dividends) is not, a separate tax on corporate income is neutral.


Because the asset will be productive for a substantial period of time, companies can only deduct a portion of the value of the asset.
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Accelerated Depreciation加速折旧
Typically, assets are allowed to be depreciated on a straight-line basis, which means in equal increments for the life of the asset. 10

Inflation and Depreciation通货膨胀与折旧

Accelerated depreciation allows businesses to deduct the loss in the value of an asset before the asset actually wears out.

The ultimate in accelerated depreciation is the allowance for expensing an asset in the year it is purchased.
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Undistributed Corporate Profits, Dividends, And Interest Cost未分配公司利润、股利及 利息成本

Some argue that a separate corporate income formula is necessary to reverse the tax preference that comes from the exclusion of all unrealized capital gains in calculating personal income tax.


Arguments in Favor of Double Taxing Corporate Income
Unrealized Capital Gains and the Stepped-Up Basis: A major source of unrealized capital gains for individuals is corporate stocks. If the business profit were not taxed at the corporate level, it might never be taxed. Compensation for Bankruptcy Protection: Individuals are not liable for the bankruptcy of assets they hold in corporations, whereas they are liable in cases of proprietorships and partnerships. This poses a real advantage to investing in corporations over the other business forms.
The fraction of all of the above that applies for each shareholder is the number of shares held divided by the total number of shares outstanding. 4
Corporate Taxes
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Corporate Profits and Where They Go

Corporate Profits = Corporate Taxes + Retained Earnings + Dividends
Retained Earnings are the portion of after-tax corporate profits that a company keeps to invest in the business. Dividends are the portion of after-tax corporate profits that are distributed to shareholders.
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Taxation of Owner-Supplied Inputs对所 有者本人提供投入品的课税问题



In small business settings, owners work for themselves. The profit from the business is what each owner is “paid.” Some of this is normal profit; some is economic profit. Corporations feature no owner-supplied input so all profit, normal and economic, is taxed.

If inflation is running at a significant pace, then the replacement cost for a capital asset can be higher than the value remaining on the books. Depreciation is understated if firms are only allowed to use historic costs.
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Economic Depreciation经济折旧

Economic Depreciation is the amount of value that an asset loses over time.
When a business buys an expensive capital asset, it cannot deduct from corporate profits the entire value of the asset.
It cannot deduct the dividends it pays to its stockholders. This encourages debt finance over equity finance. 15


Demonstrating the Bias toward Debt Finance

Corporations are subject to a corporate income tax in the U.S.
Since the corporation is not really a person, the people who bear the burden of this tax depend on the shifting of the tax. 税负会转移 The tax could be shifted backwards to employees, shifted forward to consumers or borne by the shareholders. 税收可前转或后转 5
Assumptions:10% interest; 34% tax rate
Chapter 15 Taxation of Corporate Income 公司所得税
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Forms of Business

Sole Proprietorships独资 Partnerships合伙企业 美国企业 总数的75% Corporations 公司：美国总营业收入 的90%
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Corporations公司
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The Consequence of Double Taxation: A Bias Toward Debt Finance

A corporation can raise money by borrowing (taking on debt), or it can raise money by selling stock. The corporation can deduct from its profits the amount it pays in interest to its bondholders.
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Double Taxation of Corporate Income对公 司收入的双重课税

Corporate Income is considered to be double-taxed, because its income is taxed twice. The Corporation must pay taxes on the profits, then shareholders must pay taxes on the amount they receive in either dividends or capital gains. Under a comprehensive income tax this would not happen. Corporate profits, either retained or paid in dividends, would enter individual income tax structures according to the percentage of the corporation owned by each shareholder. 13