International Taxation of Trust Income: Principles, Planning and Design by Mark

Description: International Taxation of Trust Income by Mark Brabazon This 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 and will appeal to international tax practitioners, administrators, policymakers, academics, and students. FORMAT Hardcover LANGUAGE English CONDITION Brand New Publisher Description 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. Author Biography Mark Brabazon SC is an Australian barrister with over thirty-five years of experience in legal practice and a member of 7 Wentworth Selborne, Sydney. He holds a Ph.D. from the University pf Sydney and B.A. and LL.M. degrees from the University of Queensland. He advises and represents taxpayers and revenue authorities and appears as counsel in tax, equity and commercial disputes at all levels. He also chairs the Council of Law Reporting for New South Wales. Table of 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. Review This original survey of how four countries have decided to tax trusts makes an interesting comparison reflecting their different choices for dealing with the same topic. The book manages to deal with the mass of conflicting methods while at the same time keeping an eye on the policy of what the countries are trying to achieve. John Avery Jones, Former Judge of the UK Upper TribunalThis book is essential reading for anyone concerned with trust taxation in an international setting. A meticulous analysis of four countries draws out the principles and policies of general importance underlying the taxation of trust income in cross-border situations. The discussion of interactions among these countries and with tax treaties reveals a myriad of issues for taxpayers and legislators alike, leading to proposals for a wide range of practical measures to achieve greater international coherence. Its lucid analysis and clear writing style make this book a pleasure to read. Joanna Wheeler, International Bureau of Fiscal Documentation (IBFD), The Netherlands and Universiteit van AmsterdamIts strong theoretical analysis will hopefully encourage practitioners, academics and policymakers to think through proposed trust taxation changes more rigorously and coherently, and encourage further academic research. If you are a practitioner at all interested in policy, I strongly recommend you read this book. Emma Chamberlain, Trust Quarterly Review Promotional Identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust. Review Quote This original survey of how four countries have decided to tax trusts makes an interesting comparison reflecting their different choices for dealing with the same topic. The book manages to deal with the mass of conflicting methods while at the same time keeping an eye on the policy of what the countries are trying to achieve. John Avery Jones, Former Judge of the UK Upper Tribunal Promotional "Headline" Identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust. Description for Bookstore This 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 and will appeal to international tax practitioners, administrators, policymakers, academics, and students. Description for Library This 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 and will appeal to international tax practitioners, administrators, policymakers, academics, and students. Details ISBN1108492258 Author Mark Brabazon Publisher Cambridge University Press Year 2019 ISBN-10 1108492258 ISBN-13 9781108492256 Format Hardcover Imprint Cambridge University Press Place of Publication Cambridge Country of Publication United Kingdom DEWEY 343.064 Pages 414 Illustrations Worked examples or Exercises; 10 Tables, black and white; 3 Halftones, black and white; 5 Line drawings, black and white Publication Date 2019-05-02 Series Cambridge Tax Law Series Subtitle Principles, Planning and Design Language English UK Release Date 2019-05-02 AU Release Date 2019-05-02 NZ Release Date 2019-05-02 Alternative 9781108679299 Audience Tertiary & Higher Education We've got this At The Nile, if you're looking for it, we've got it. With fast shipping, low prices, friendly service and well over a million items - you're bound to find what you want, at a price you'll love! TheNile_Item_ID:168640974;

Price: 300.6 AUD

Location: Melbourne

End Time: 2024-12-24T03:07:29.000Z

Shipping Cost: 13.68 AUD