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美国并购重组税制的立法原则包括资本利得与经营收益相区别原则、应税交易与免税交易相区别原则、持续经营原则和交易型评估与税务型评估相结合原则。我国的并购重组税制则是通过对企业所得税法规的补充逐步形成的,立法原则不鲜明。美国的立法经验值得我们学习和借鉴。
The legislative principles of the merger and reorganization tax system in the United States include the principle of distinguishing between capital gains and operating profits, the principle of distinguishing between taxable transactions and tax-exempt transactions, the principle of going concern, and the combination of transactional evaluation and taxation evaluation. The M & A and restructuring tax system in our country is gradually formed through the supplement of the corporate income tax laws and regulations, and the principle of legislation is not clear. The legislative experience in the United States deserves our study and reference.