Traduction de «état intégré des bénéfices non répartis » (Français → Anglais) :

8. Notwithstanding the provisions of paragraph 5, a company which is a resident of Canada and which has income subject to tax in the United States (without regard to the provisions of the Convention) may be liable to the United States accumulated earnings tax and personal holding company tax but only if 50 per cent or more in value of the outstanding voting shares of the company is owned, directly or indirectly, throughout the last half of its taxable year by citizens or residents of the United States (other than citizens of Canada who do not have immigrant status in the United States or who have not been residents in the United States f ...[+++]or more than three taxable years) or by residents of a third State.

An inability of firms to retain earnings because they're being taxed to death is another means by which.Equity financing, retained earnings within the firm are also hugely important sources of capital.

Once the tax base of the company has been established, the company's taxable profits will be shared out between the Member States in which the company is active using an apportionment formula (see below).

Regarding penalties, it introduces a principle of "aggravating circumstance" by providing that "terrorist offences" and certain offences linked to terrorism must be punishable by custodial sentences heavier than those imposable under national law for such offences in the absence of a terrorist intent, it sets the minimum level of the maximum penalty at 15 years for directing a terrorist group and 8 years for participation in a terrorist group, it enumerates a series of penalties that can be imposed on bodies corporate (in particular exclusion from entitlement to public benefits or aid, temporary or permanent disqualification from the pra ...[+++]ctice of commercial activities, placing under judicial supervision, judicial winding-up order and closure of establishments), it provides for a system of "repentis" by providing for specific circumstances in which Member States may reduce prison sentences where the terrorist renounces terrorist activity or provides the administrative or judicial authorities with information.

- to improve the situation as regards recovery so that the financial burden is shared out correctly among the Member States, i.e. it must be borne by the country which has enjoyed the economic benefit of the transaction.

That integration, and the supporting policy actions to help the catching-up process of the less favoured regions, will boost employment and efforts must be made to ensure that the benefits are distributed fairly to all parts of the Community and to all social groups.