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Vol 24 No 9 Sept/Oct 2019

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International Taxation of Trust Income


ISBN13: 9781108492256
Published: June 2019
Publisher: Cambridge University Press
Country of Publication: UK
Format: Hardback
Price: £95.00



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£76.00
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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 U.K., and the U.S., 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

Subjects:
Taxation
Contents:
Figures
Tables
Preface
Cases
Statutes
Other Authorities
Treaties
Abbreviations
Glossary
1. Introduction
Part I. National Tax Laws:
2. The Grantor
3. The Beneficiary
4. The Trust
5. Distributions
6. International Taxation
Part II. Global Taxation:
7. The International Tax Order and the Interaction of Tax Laws
8. Treaties
9. Conclusions and Proposals – Taxing the Shadow
10. Appendix: Detail of Beneficiary Attribution and Taxation 389
Bibliography
Index

Series: Cambridge Tax Law

International Taxation of Trust Income (eBook) ISBN 9781108630207
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The Victorian Taxpayer and the Law: A Study in Constitutional Conflict ISBN 9780521899246
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Published November 2006
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