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مقاله ترجمه شده با عنوان تحقق سود و جدایی از سرمایه
مقاله ترجمه شده با عنوان تحقق سود و جدایی از سرمایه در فرمت ورد و شامل ترجمه متن زیر می باشد:
Realization of income and separation from capital
The
concepts of economic income and realized income have been subjects of
controversy for a long time in corporate accounting and related areas.
Those arguments have been repeated in a variety of forms, not only in
attempts to reconsider the concept of income in the light of economic
income but also in the related area such as taxation on corporate income
and restrictions on dividend for the company law purpose. In this
section, take a quick look at an early judicial precedent in US 6), as a
clue to a review of the process of interaction of income concept and
establishment of realization concepts.
The
judicial precedent at issue is the case of Eisner vs. Macomber ruled by
the US Federal Supreme Court in 1920. Although this case was originally
a dispute over the provision of the Internal Revenue Code that deemed
stock dividends as taxable income, it became a leading case that left a
significant impact to posterity, in that it established the conceptual
norms such as what constitutes income. The court decision set out the
interpretation of the realization concept that a mere increase in the
value of capital is not enough to constitute income if it is not
separated from capital, thereby denied that stock dividend is income.
The court decision defined the income generated from capital as an
inflow of goods that has been separated from capital and the recipient
can independently use or dispose of, not a mere increase in the value of
the capital. It pointed out that, whereas in case of cash dividends the
shareholders acquire a property with exclusive ownership and can freely
decide its disposal, stock dividend provides only an evidence of what
the shareholders already holds. It also noted that the increase in the
value of capital arising before the dividend should not be deemed as
realization of income, as long as the shareholders do not have
discretion to reinvest or consume it.
This
was an attempt to describe the “inflow of cash or cash equivalent” test
for realization of income, which had already been established with
regard to taxation on capital gains, using more essential attributes.
This rule, which deems the increase of the value realized separately
from capital as income, tried to derive the accounting concept of
realized income by adding the “availability for consumption” condition,
whereas it started from the concept of economic income, that is, value
increase arising on capital. However, separation from capital would not
be necessary, if satisfaction of the “availability for consumption”
condition were just enough. Even before the cash flow is realized, an
increment in capital value is consumable through borrowing. Even though
the increment is not separated from capital, capital is maintained as
far as the surplus is consumed. It follows that the “availability for
consumption” condition can be also met by economic income. Although
stock dividend itself has nothing to do with the income of shareholders,
the increase in the value of their interest, resulted from accumulation
of earnings before that, should have brought consumable income to the
shareholders.
Nevertheless,
this court decision determined that the shareholders’ equity in
retained earnings is capital, not income. The basic stance of this
decision was that income is cash flow, not the expectation of it. Stock
dividend was excluded from the income of the shareholders because it
neither makes the company worse off nor the shareholders better off. A
transfer of wealth involving cash flows (that is, realized income), not
mere appreciation of capital value, was the element of income as defined
here. The above discussion reveals that the realized income as an
accounting concept should be viewed as a concept conflicting with the
economic income concept ab initio, rather than a subordinated concept
derived from that. It was not a concept derived from the economic income
by imposing an additional condition. Instead, it seems that realization
as cash flows was regarded as a necessary condition from the beginning
and that condition was explained by the concept of separation from
capital. This means that economic income and realized income are
independent concepts with different objectives and origins. Although
they can be compared with each other, consistency between them cannot be
expected.
