This book explores the concept of beneficial ownership in equity law, the domestic tax laws of the United Kingdom, Canada and the United States, as well as its varied and increasing uses in international tax law. By analysing the evolution of beneficiary rights in equity and the use of beneficial ownership wording in tax law, the book draws a roadmap for dealing with beneficial ownership in both national and international tax law. This approach highlights those common misconceptions that can be avoided by understanding the origins of the concept and its engagement with equity, as well as the differences with tax law. However, the book does not limit itself to dealing with theoretical discussion, but also offers an instructive and detailed practical case study. Offering both academic commentary and a practitioner focus, the book will be of the utmost interest to scholars and practitioners from common and civil law countries dealing with tax and estate law, particularly given beneficial ownership's increasing relevance.
Pablo A Hernandez Gonzalez-Barreda (Universidad Pontificia Comillas Spain)
Country of Publication:
28 May 2020
Professional and scholarly
Preface and Acknowledgements Patricia Owens and Katharina Rietzler; Introduction: Toward a History of Women's International Thought Patricia Owens and Katharina Rietzler; I. Canonical Thinkers: 1. Anna Julia Cooper on Slavery's Afterlife: Can International Thought 'Hear' Her 'Muffled' Voice and Ideas? Vivian M. May; 2. Revolutionary Thinking: Luxemburg's Socialist International Theory Kimberley Hutchings; 3. Of Colonialism and Corpses: Simone Weil on Force Helen M. Kinsella; 4. Ideas in Action: Eslanda Robeson's International Thought After 1945 Imaobong Umoren; II. Outsiders: 5. Elizabeth Lippincott McQueen: Thinking International Peace in an Air-Minded Age Tamson Pietsch; 6. Women of the Twenty Years' Crisis: The Women's International League for Peace and Freedom and the Problem of Collective Security Lucian Ashworth; 7. Theorizing (with) Amy Ashwood Garvey Robbie Shilliam; 8. 'The Dark Skin[ned] People of the Eastern World': Mittie Maude Lena Gordon's Vision of Afro-Asian Solidarity Keisha N. Blain; 9. Elizabeth Wiskemann, Scholar-Journalist, and the Study of International Relations Geoffrey Field; III. Thinking In or Around the Academy: 10. From F. Melian Stawell to E. Greene Balch: International and Internationalist Thinking at the Gender Margins, 1919-1947 Glenda Sluga; 11. Race, Gender, Empire, and War in the International Thought of Emily Greene Balch Catia Confortini; 12. Beyond Illusions: Imperialism, Race and Technology in Merze Tate's International Thought Barbara Savage; 13. A Plan for Plenty: The International Thought of Barbara Wootton Or Rosenboim; 14. Collective Security for Common Men and Women: Vera Micheles Dean and U.S. Foreign Relations Andrew Jewett; 15. What Can We (She) Know About Sovereignty? Krystyna Marek and the Worldedness of International Law Natasha Wheatley.
Pablo A Hernandez Gonzalez-Barreda is lecturer in law at the Universidad Pontificia Comillas, Spain.
Reviews for Beneficial Ownership in Tax Law and Tax Treaties
From the foreword: We in the United Kingdom think we know what beneficial ownership means, although the author is right in saying that we cannot explain it, and we think we know what it must have been intended to mean in tax treaties, but it required Pablo Hernandez from Spain to make us see all the contradictions that are involved and make sense of them by including interesting civil law comparisons. -- Dr John Avery Jones CBE