On The Continuity Of Interest Doctrine Of The Corporation Income Tax In Tax-Free Reorganization

The economy of our country is developing rapidly and corporations are badly in need of expanding themselves through mergers and reorganization. But the imperfection of the tax-free provisions in our country hinder that progress. In this condition, it is necessary to reform the tax-free provisions in our country. To do research on tax-free reorganization provisions, it’s better to find a appropriate point of penetration. In this sense, the continuity of interest doctrine seems an optimal one. Tax law in our country just begin to develop in recent decades and there are many reference of tax system in other countries. Although the present provision reflect some points of the continuity of interest doctrine, the essence of the doctrine is vague to some extent. In this research, we reexamine the enactment progress of the USA to help find the real essence of the continuity of interest doctrine and with this we can better interpret it and combine it with the special circumstance in our country. Compared to the previous research,this research is done from a different perspective and focus more on the essence of the doctrine instead of just compare the whole regime to another one.