PERHAPS A GIFT VOUCHER FOR MUM?: MOTHER'S DAY

Close Notification

Your cart does not contain any items

International Taxation of Trust Income

Principles, Planning and Design

Mark Brabazon

$50.95

Paperback

Not in-store but you can order this
How long will it take?

QTY:

English
Cambridge University Press
30 June 2022
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.

By:  
Imprint:   Cambridge University Press
Country of Publication:   United Kingdom
Dimensions:   Height: 229mm,  Width: 152mm,  Spine: 23mm
Weight:   600g
ISBN:   9781108729178
ISBN 10:   1108729177
Series:   Cambridge Tax Law Series
Pages:   415
Publication Date:  
Audience:   Professional and scholarly ,  Undergraduate
Format:   Paperback
Publisher's Status:   Active
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.

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.

Reviews for International Taxation of Trust Income: Principles, Planning and Design

'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 'This 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 Amsterdam 'Its 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


See Also