Tax Glossary

Term used in relation to the importation of goods which means the sum total of the cost of the goods concerned, the amount of customs duties levied on those goods and the expense incurred in unloading them.

In general, a lease is a contract in respect of real or personal property, under which the owner of the property grants to another the right to possess, use and enjoy the property for a specified period in exchange for periodic payments.

Corporations, joint-stock companies and limited liability companies are regarded for tax purposes as having an existence separate from that of their shareholders. Conversely, for tax purposes a partnership is often not regarded as a separate legal entity, its profits being taxed in the hands of the individual partners. What constitutes a legal entity for tax purposes may or may not coincide with what constitutes a legal entity for general law purposes.

Under civil law corporations are required to maintain a legal reserve for all needs which may arise during the business. Tax law does not allow a deduction for such a reserve.

A company which has compiled only the essentials for organization and registration in a particular country. The actual commercial activities are conducted in another country.

This term denotes reducing, by means of tax policy, the differences in the taxation of internationally mobile entities or transactions allowing countries to compete fairly on non-tax factors.

Annual duties payable for the privilege of carrying on a certain trade.

Licensing is an agreement by which a licensor transfers the right to use his technology and/or know-how to a licensee for the production or manufacturing of a product in the licensee's country. Royalties are paid for the right to use the technology or know-how.

A charge against property, making it security for the payment of a debt, judgment, mortgage, or taxes.

Assets may be given to a person for his lifetime use or benefit, with the stipulation that after his (the life tenant's) life, the assets will pass to another beneficiary.

Under common law an interest in possession whereby the individual beneficiary is entitled to the income of a trust or settlement until his death.

Method ("last in, first out") of valuing inventory or stock-in-trade whereby the goods or materials purchased last are regarded as those which are sold first.

Properties of the same nature or character, even if they differ in grade or quality.

Tax treaty provisions are designed to restrict treaty-shopping opportunities by limiting treaty benefits to persons who meet one of several enumerated tests, which may require minimum level qualifications, e.g., local ownership.

Liability of investor which is limited to the extent of his investment.

An entity formed under state law by filing articles of organization as an LLC. Unlike a partnership, none of the members of an LLC are personally liable for its debts. An LLC may be classified for federal income tax purposes as a partnership, a corporation, or an entity disregarded as an entity separate from its owner by applying the rules in the Treasury Regulations, section 301.7701-3.

A partnership formed under a state limited liability partnership law. Generally, a partner in an LLP is not personally liable for the debts of the LLP or any other partner, nor is a partner liable for the acts or omissions of any other partner, solely by reason of being a partner.

A partnership formed under a state's limited partnership law and composed of at least one general partner and one or more limited partners.

Structure operating because of the different rules in various countries for determining the place of residence; it is a means used by dual resident companies to obtain tax relief in two countries.

A company in liquidation is a company in the process of being dissolved or wound up, and its assets, if any, after payment of its debts, distributed to the shareholders.

Company whose shares are traded on a recognized stock exchange.

Items specifically named (listed) in IRS code as subject to special rules for depreciation. Listed property includes passenger automobiles and any other property used for transportation; property of a type used generally for entertainment, recreation, or amusement; computers and their peripheral equipment (unless used only at a regular business establishment and owned or leased by the person operating the establishment); and cellular telephones or similar telecommunications equipment.

The costs incurred to obtain a loan.

In countries where there is a central or federal government and separate levels of government at state, provincial, county or city levels, taxes levied at the lower levels of government are commonly referred to as "local" taxes.

The location of an asset is relevant to the determination of whether it is within a taxing authority's jurisdiction. Location of immovable property in a country means, in most countries, that the country taxes the income derived therefrom and possibly the value and capital gains realized on alienation, even if the owner is not a resident of that country.

The term used in the context of transfer pricing refers to the savings or benefits such as cheaper production or service costs obtained by sitting manufacturing operations in an offshore jurisdiction.

In countries where capital gains are subject to special tax treatment, a distinction may be made between capital gains realized after a short period of time and capital gains realized after a longer period. Long-term capital gains may be taxed at reduced rates.

A period of more than one year.

Term typically used when disregarding the separate legal identity, for example, a company, in order to charge tax on a shareholder in respect of his share of the company profits.

Opportunities available in tax law to minimize a taxpayer's tax burdens.

Most income tax laws provide some form of relief for losses incurred, either by carrying over the loss to offset it against profits in previous years (carry-back) or in future years (carry-forward) or by setting off the loss against other income of the same taxpayer in the year in which the loss was incurred.

The term may broadly be defined as the excess of expenses over revenues for a period, or the excess of the cost of assets over the proceeds when the assets are sold or otherwise disposed of, or abandoned or destroyed.

Deduction, often from income, for the computation of taxable income, which does not reflect the factual situation.

The distribution or payment made in one tax year of a plan participant's entire balance from all of the employer's qualified plans of one kind; for example, pension, profit-sharing, or stock bonus plan.

A vehicle for which the depreciation deduction is limited because of its purchase price.

Indirect ad valorem tax imposed on supplies of specific non-essential and normally expensive commodities.