Comparative Income Taxation

Author : Hugh J. Ault,Brian J. Arnold
Publisher : Kluwer Law International B.V.
Page : 594 pages
File Size : 46,9 Mb
Release : 2010-01-01
Category : Business & Economics
ISBN : 9789041132048

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Comparative Income Taxation by Hugh J. Ault,Brian J. Arnold Pdf

The purpose of this book is to compare different solutions adopted by nine industrialized countries to common problems of income tax design. As in other legal domains, comparative study of income taxation can provide fresh perspectives from which to examine a particular national system. Increasing economic globalization also makes understanding foreign tax systems relevant to a growing set of transnational business transactions. Comparative study is, however, notoriously difficult. Full understanding of a foreign tax system may require mastery not only of a foreign language, but also of foreign business and legal cultures. It would be the work of a lifetime for a single individual to achieve that level of understanding of the nine income taxes compared in this volume. Suppose, however, that an international group of tax law professors, each expert in his own national system, were asked to describe how that system resolved specific problems of income tax design with respect to individuals, business organizations, and international transactions. Suppose further that the leaders of the group wove the resulting answers into a single continuous exposition, which was then reviewed and critiqued by a wider group of tax teachers. The resulting text would provide a convenient and comprehensive introduction to foreign approaches to income taxation for teachers, students, policy-makers and practitioners. That is the path followed by Hugh Ault and Brian Arnold and their collaborators in the development of this fascinating book. Henceforth, a reader interested in how other developed countries resolve such structural issues as the taxation of fringe benefits, the effect of unrealized appreciation at death, the classification of business entities, expatriation to avoid taxes, and so on, can turn to this volume for an initial answer. This book should greatly facilitate comparative analysis in teaching and writing about taxation in the US and elsewhere.

Author : Brian J. Arnold,Hugh J. Ault,Graeme Cooper
Publisher : Kluwer Law International B.V.
Page : 655 pages
File Size : 54,6 Mb
Release : 2019-12-09
Category : Law
ISBN : 9789403510903

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Comparative Income Taxation by Brian J. Arnold,Hugh J. Ault,Graeme Cooper Pdf

Comparative Income Taxation A Structural Analysis Fourth Edition Hugh J. Ault, Brian J. Arnold & Graeme S. Cooper In complex national income tax systems, structural and design variations from one country to another present major obstacles to the kind of comparative understanding that economic globalization requires. Hence the great significance of this outstanding book, highly acclaimed through three previous editions and now thoroughly updated to encompass the latest changes and trends. In it, leading authorities from eleven of the world’s most important national taxation systems each contribute their particular expertise to a study of specific crucial problems of tax design. In addition to the nine countries covered in previous editions—Australia, Canada, France, Germany, Japan, the Netherlands, Sweden, the United Kingdom and the United States—China and India have now been added to provide the perspective of developing countries. Individually authored country descriptions outline the climate and institutional framework in which each of the eleven national taxation systems’ substantive rules operate. All the country descriptions are analyzed in accordance with a common format to facilitate comparisons of the ways in which the countries’ tax systems are similar and in which they differ. They form the background to an expertly informed comparative analysis focusing on three major areas: basic income taxation, taxation of business organizations and international taxation. Most of the rules especially important for international business and investment are dealt with here, including (among many others) rules on the following: classification of business entities; taxation of corporations and their shareholders; corporate organization and restructuring; taxation of partnerships; residence and source taxation; controlled foreign company rules; restrictions on the deduction of interest; courts dealing with tax matters; and effect of tax treaties. Several new topics—including the classification of employees and independent contractors, the taxation of pensions, patent box regimes, the taxation of indirect transfers and the tax challenges of the digital economy—have been added. Especially timely are discussions of changes stemming from the G20/OECD Base Erosion and Profit Shifting project. The introduction has also been expanded to include a new section on European Union (EU) law as it affects the tax laws of EU Member States. This new edition of a classic source of information and analysis for students, professors, researchers, tax practitioners and tax policy officials on the different ways that countries design their income tax systems will be widely welcomed by the international tax community.

Author : Hugh J. Ault
Publisher : Unknown
Page : 540 pages
File Size : 42,7 Mb
Release : 1997
Category : Electronic
ISBN : 8041108814

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Comparative Income Taxation : a Structural Analysis by Hugh J. Ault Pdf

Author : Hugh J. Ault
Publisher : Unknown
Page : 0 pages
File Size : 50,6 Mb
Release : 1997
Category : Income tax
ISBN : OCLC:1409186961

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Comparative Income Taxation by Hugh J. Ault Pdf

Author : Caren Grown,Imraan Valodia
Publisher : IDRC
Page : 349 pages
File Size : 54,6 Mb
Release : 2010
Category : Business & Economics
ISBN : 9780415568227

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Taxation and Gender Equity by Caren Grown,Imraan Valodia Pdf

Around the world, there are concerns that many tax codes are biased against women, and that contemporary tax reforms tend to increase the incidence of taxation on the poorest women while failing to generate enough revenue to fund the programs needed to improve these women's lives. Because taxes are the key source of revenue governments themselves raise, understanding the nature and composition of taxation and current tax reform efforts is key to reducing poverty, providing sufficient revenue for public expenditure, and achieving social justice. This is the first book to systematically examine gender and taxation within and across countries at different levels of development. It presents original research on the gender dimensions of personal income taxes, and value-added, excise, and fuel taxes in Argentina, Ghana, India, Mexico, Morocco, South Africa, Uganda and the United Kingdom. This book will be of interest to postgraduates and researchers studying Public Finance, International Economics, Development Studies, Gender Studies, and International Relations, among other disciplines.

Author : Steffen Ganghof
Publisher : ECPR Press
Page : 209 pages
File Size : 54,6 Mb
Release : 2006
Category : Business & Economics
ISBN : 9780954796686

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The Politics of Income Taxation by Steffen Ganghof Pdf

Marginal income tax rates in advanced industrial countries have fallen dramatically since the mid-1980s, but levels and progressivity of income taxation continue to differ strongly across countries. This study offers a new perspective on both observations. It blends theoretical inquiry with focused quantitative analysis and in-depth investigation of seven countries: Germany, Australia and New Zealand as well as Denmark, Finland, Norway and Sweden. The Politics of Income Taxation highlights the equity-efficiency tradeoffs that structure the politics of income taxation, and analyses how income taxes are embedded in broader tax systems. It explains the limited but enduring importance of political parties and democratic institutions. Finally, the study paints a nuanced picture of the role of globalisation and thus sheds light on the pros and cons of tax coordination at European and international levels.

Author : Hugh J. Ault
Publisher : Unknown
Page : 0 pages
File Size : 46,7 Mb
Release : 2010
Category : Income tax
ISBN : 1454888202

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Comparative Income Taxation by Hugh J. Ault Pdf

Author : Mervyn A. King,Don Fullerton
Publisher : University of Chicago Press
Page : 361 pages
File Size : 47,5 Mb
Release : 2010-06-15
Category : Business & Economics
ISBN : 9780226436319

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The Taxation of Income from Capital by Mervyn A. King,Don Fullerton Pdf

Taxation—both corporate and personal—has been held responsible for the low investment and productivity growth rates experienced in the West during the last decade. This book, a comparative study of the taxation of income from capital in the United States, the United Kingdom, Sweden, and West Germany, establishes for the first time a common framework for analysis that permits accurate comparison of tax systems.

Author : Chris Evans,Lymer Andy,Sandford Cedric
Publisher : Unknown
Page : 339 pages
File Size : 42,5 Mb
Release : 2017-08-15
Category : Business & Economics
ISBN : 1906201374

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Comparative Taxation by Chris Evans,Lymer Andy,Sandford Cedric Pdf

This book compares and contrasts tax systems in developed and developing countries. It addresses; the taxation of incomes, wealth and consumption at the local, national, supranational and international levels; environmental taxes; modern trends in tax admin; and tax reform.

Author : Victor Thuronyi,Kim Brooks
Publisher : Kluwer Law International B.V.
Page : 362 pages
File Size : 48,7 Mb
Release : 2016-04-20
Category : Law
ISBN : 9789041167200

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Comparative Tax Law by Victor Thuronyi,Kim Brooks Pdf

Although the details of tax law are literally endless—differing not only from jurisdiction to jurisdiction but also from day-to-day—structures and patterns exist across tax systems that can be understood with relative ease. This book, now in an updated new edition, focuses on these essential patterns. It provides an immensely useful introduction to the core common knowledge that any well-informed tax lawyer or policy maker should have about comparative tax law in our times. The busy reader will welcome the compact nature of this work, which is shorter than the first edition and can be read in a weekend if one skips footnotes. The authors elucidate the commonalities and differences across countries in areas including (much of the detail new to the second edition): • general anti-avoidance rules; • court decisions striking down tax laws as violating constitutional rules against retroactivity, unequal treatment of equals, confiscation, and undue vagueness; • statutory interpretation; • inflation adjustment rules and the allowance for corporate equity; • value added tax systems; • concepts such as “tax”, “capital gain”, “tax avoidance”, and “partnership”; • corporate-shareholder tax systems; • the relationship between tax and financial accounting; • taxation of investment income; • tax authorities’ ability to obtain and process information about taxpayers; and • systems of appeals from tax assessments. The information and analysis pull together valuable material which is scattered over a disparate literature, much of it not available in English. Especially considering the dynamic nature of tax law, whose rate of change exceeds that of any other field of law, the authors’ clear identification of the underlying patterns and fundamental structures that all tax systems have in common—as well as where the differences lie—guides the reader and offers resources for further research.

Author : Reuven Shlomo Avi-Yonah,Nicola Sartori,Omri Marian
Publisher : Oxford University Press, USA
Page : 202 pages
File Size : 47,8 Mb
Release : 2011
Category : Law
ISBN : 9780195321364

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Global Perspectives on Income Taxation Law by Reuven Shlomo Avi-Yonah,Nicola Sartori,Omri Marian Pdf

In 'Global Perspectives on Income Taxation Law', Avi-Yonah covers basic, corporate and international tax law from a comparative perspective. The book both supplements readings in U.S. tax law courses and serves as a textbook for a comparative tax law class.

Author : Karen B. Brown
Publisher : Springer
Page : 0 pages
File Size : 54,9 Mb
Release : 2017-01-23
Category : Law
ISBN : 3319421557

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Taxation and Development - A Comparative Study by Karen B. Brown Pdf

This volume examines the tax systems of some twenty countries to determine whether their tax laws are used to support growth and development across borders in lower-income and poor countries. Given the critical economic development needs of poorer countries and the importance of stability in these regions to the security of populations throughout the world, the use of a country’s tax laws to support investment in the developing world gains crucial significance. This book explores whether international standards promoting the fundamental values of the major tax systems of the world accommodate incentives for these nations. In addition, it analyzes the way in which adoption of principles by higher income nations to protect their own revenue bases has a spill-over effect, impairing the ability of developing countries to sustain their economies. Following an introduction that synthesizes worldwide trends, the volume contains separate chapters for a variety of countries detailing the underlying goals and values of each system and the way in which the decision to employ (or not employ) incentives accommodates those ends. The chapters include reports for: Australia, Belgium, Brazil, Croatia, Czech Republic, France, Hong Kong, Israel, Italy, Japan, the Maldives, the Netherlands, Poland, Portugal, South Africa, Uganda, United Kingdom, United States, and Venezuela. The volume memorializes the work of the General Reporter and National Reporters at the Taxation and Development session of the 19th Congress of the International Academy of Comparative Law held in July, 2014, in Vienna, Austria.

Author : Michael Littlewood,Craig Elliffe
Publisher : Edward Elgar Publishing
Page : 448 pages
File Size : 51,7 Mb
Release : 2017-08-25
Category : Law
ISBN : 9781784716028

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Capital Gains Taxation by Michael Littlewood,Craig Elliffe Pdf

Capital gains taxes pose a host of technical and political design problems and yet, while the literature on the theory of capital gains taxation is substantial, little has been published on how governments have addressed these dilemmas. Written by a team of distinguished international experts, Capital Gains Taxation addresses the gap in the literature; it explains how a number of countries tax capital gains and the successes and pitfalls of these methods.

Author : Christopher Hanna
Publisher : Springer
Page : 0 pages
File Size : 42,8 Mb
Release : 2000-08-07
Category : Business & Economics
ISBN : 9041197710

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Comparative Income Tax Deferral of the United States and Japan by Christopher Hanna Pdf

Comparative Income Tax Deferral examines the benefits achieved by deferring income or accelerating deductions, with reference to the income tax systems of the United States and Japan. The United States has been at the forefront of recognising the time value of money benefit of tax deferral and of devising methods to prevent tax deferral. Japan, on the other hand, is only gradually placing greater emphasis on tax deferral issues, in light of the activities of foreign companies, and the constant introduction of new financial products which take advantage of the tax deferral allowed under Japanese income tax rules. The book starts with a detailed discussion of the 1948 Cary Brown model and its various interpretations, an understanding of which is key to any analysis of tax deferral issues. The author goes on to provide a comparative analysis of the different tax deferral patterns that can arise under the United States and Japanese income tax systems, and of methods introduced by the United States to eliminate the tax deferral benefit. A history and overview of the Japanese income tax system is included in the appendix. Principles of tax deferral and time value of money are crucial in an era of globalisation in commerce and finance. They cut across all areas of taxation and are particularly important in the context of taxation of derivatives and other financial instruments. This book is an important addition to the literature in this field and will be of great interest to tax and business law practitioners, investment bankers and financial planners.

Author : Cedric Sandford
Publisher : Unknown
Page : 232 pages
File Size : 51,5 Mb
Release : 2000
Category : Business & Economics
ISBN : STANFORD:36105025268017

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Why Tax Systems Differ by Cedric Sandford Pdf

Analysis and comparison of taxation in different countries, looking at what tax systems have in common, how they differ and trying to explain both the similarities and the diffences. The first part concerns tax structures. The second part looks at individual taxes or related groups of taxes. The third section deals with some aspects of policy-making and tax administation.