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Cambridge Tax Law Series

International Taxation of Trust Income

Principles, Planning and Design

Mark Brabazon

International Taxation of Trust Income

Cambridge Tax Law Series

International Taxation of Trust Income

Principles, Planning and Design

Cambridge Tax Law Series: International Taxation of Trust Income

 

"This book presents the principles and design of international taxation of trust income and distributions as a coherent subject of international tax law. It begins with the trust tax rules and international settings of four countries -- Australia, New Zealand, the United Kingdom and the United States -- focusing on the attribution of trust income to the grantor/settlor, the beneficiary or the trust entity, trust residence, and the taxation of trust distributions.


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Beschrijving Cambridge Tax Law Series: International Taxation of Trust Income

In International Taxation of Trust Income, Mark Brabazon establishes the study of international taxation of trust income as a globally coherent subject. Covering the international tax settings of Australia, New Zealand, the UK, and the US, and their taxation of grantors/settlors, beneficiaries, trusts, and trust distributions, the book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust. It also identifies international mismatches between tax settings and purely domestic design irregularities that cause anomalous double- or non-taxation, and proposes an approach to tax design that recognises the policy functions (including anti-avoidance) of particular rules, the relative priority of different tax claims, the fiscal sovereignty of each country, and the respective roles of national laws and tax treaties. Finally, the book includes consideration of BEPS reforms, including the transparent entity clause of the OECD Model Tax Treaty.



  • Provides the first sustained analysis of international taxation of trust income as an internationally coherent subject

    Enables international trust taxation to be studied as a topic in its own right alongside international taxation of companies and partnerships

    Facilitates a holistic approach to tax planning, analysis and design by practitioners, scholars and administrators

    Proposes tax design solutions to unintended double- and non-taxation



ISBN
9781108492256
Pagina's
414
Verschenen
Serie
Cambridge Tax Law Series
NUR
826
Druk
1
Uitvoering
Hardback
Taal
Engels
Uitgever
Cambridge University Press