Comparative Income Taxation A Structural Analysis

Author : Hugh J. Ault,Brian J. Arnold
Publisher : Kluwer Law International B.V.
Page : 594 pages
File Size : 40,8 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 : 49,9 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 : 43,6 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 : 46,9 Mb
Release : 2010
Category : Income tax
ISBN : 1454888202

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Comparative Income Taxation by Hugh J. Ault Pdf

Author : Hugh J. Ault
Publisher : Unknown
Page : 0 pages
File Size : 49,6 Mb
Release : 1997
Category : Income tax
ISBN : OCLC:1409186961

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Comparative Income Taxation by Hugh J. Ault Pdf

Author : Mr.Enrique G. Mendoza,Assaf Razin,Ms.Linda L. Tesa
Publisher : International Monetary Fund
Page : 68 pages
File Size : 46,6 Mb
Release : 1993-02
Category : Business & Economics
ISBN : UCSD:31822015073992

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A Comparative Analysis of the Structure of Tax Systems in Industrial Countries by Mr.Enrique G. Mendoza,Assaf Razin,Ms.Linda L. Tesa Pdf

A methodology for computing effective average tax rates on factor incomes and consumption using OECD data from national accounts and revenue statistics is described and applied to construct time series of tax rates for the group of seven largest industrialized countries. These tax rates are compared with estimates of effective marginal tax rates obtained in other studies. The stylized facts that distinguish tax systems across countries are documented, and the co-movements between the tax rates and savings, investment, net exports, unemployment, and hours worked are also examined. The results of this analysis illustrate some of the potential implications of tax policies currently under consideration and suggest that the proposed tax rates are useful approximations to those faced by representative agents in dynamic macroeconomic models.

Author : Yariv Brauner,Martin James McMahon
Publisher : Kluwer Law International B.V.
Page : 355 pages
File Size : 51,8 Mb
Release : 2012-03-01
Category : Law
ISBN : 9789041141989

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The Proper Tax Base by Yariv Brauner,Martin James McMahon Pdf

Virtually all objections to taxation schemes spring from perceptions of unfairness. Is tax fairness possible? The question is certainly worth investigating in depth, and that is the purpose of this book. Today, as governments are busily making new tax rules in the wake of staggering budget deficits, is perhaps an appropriate time to pay heed to fairness so it can be incorporated as far as possible into tax reform. With twelve contributions from some of the world’s most respected international tax experts—including the late Paul McDaniel, in whose honor these essays were assembled—this invaluable book focuses on tax expenditure analysis, the quest for a just income tax, and division and/or harmonization of the income tax base among jurisdictions. Among the areas of taxation ripe for reform from a fairness point of view the authors single out the following: tax expenditure budget construction; tax expenditure reporting; modern welfare economics as a driver of tax reform; grantor trust rules; the notion of “horizontal equity”; the international tax norm of “income source”; transfer pricing; and jurisdictional application of VAT. Specific ongoing reforms in the United States, Australia, and other countries—as well a detailed analysis of the EU’s proposed common consolidated corporate tax base (CCCTB)—are also examined for fairness. As a timely, high-quality resource that effectively tackles an array of salient issues, this is a book that will be read and studied by tax practitioners, corporate tax experts, government tax policy makers, advisers and consultants on the reform and design of tax systems, and international organizations involved in standard setting related to tax administration, as well as academics and researchers.

Author : Steffen Ganghof
Publisher : ECPR Press
Page : 209 pages
File Size : 50,9 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 : Victor Thuronyi,Kim Brooks
Publisher : Kluwer Law International B.V.
Page : 362 pages
File Size : 52,9 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 : Karen B. Brown
Publisher : Springer
Page : 0 pages
File Size : 40,6 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 : Aleksandra Bal
Publisher : Kluwer Law International B.V.
Page : 314 pages
File Size : 50,8 Mb
Release : 2018-11-29
Category : Law
ISBN : 9789403501048

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Taxation, Virtual Currency and Blockchain by Aleksandra Bal Pdf

The emergence of convertible decentralized virtual currency schemes confronts tax authorities with unprecedented questions, among them are the status of virtual currency for tax purposes, which virtual transactions may bene?t from a VAT exemption and determining the most optimal method of tax regulation. This ?rst book-length treatment of this major current topic provides an in-depth and comprehensive analysis of the tax implications of virtual currency transactions. Seeking to ascertain whether virtual currency requires additional regulation or whether the law as it stands is adequate to administer its usage, the analysis not only thoroughly explains the nature of the underlying blockchain technology and its regulatory and judicial treatment so far but also identi?es best practices for virtual currency transactions and makes recommendations for the improvement of the existing tax systems. Among the aspects of the phenomenon covered are the following: – particular aspects of virtual currency use such as smart contracts and initial coin offerings; – comparative review of income tax consequences of virtual currency transactions in Germany, the Netherlands, the United Kingdom and the United States; – VAT/sales tax treatment of transactions involving virtual currency in the European Union and the United States; – methodology for creating an effective regulatory framework for the taxation of virtual currency; and – the future of blockchain. The book has three parts and an annex that describes tax regulations, administrative rulings and court decisions concerning virtual currency in twenty countries. In its in-depth analysis of tax implications of virtual currency transactions in major economies, detailed overview of recent tax developments that affect virtual currency transactions and evaluation of tax policies related to virtual currencies, this book has no peers. Especially in view of the OECD's examination of the tax challenges presented by the digital economy as part of its base erosion and pro?t shifting (BEPS) project, this clear and comprehensive explanation of the functioning of virtual currency and blockchain technology will be welcomed by tax administration of?cials and by persons mining and transacting in virtual currencies needing to know their compliance obligations.

Author : Andrew Robertson,James Goudkamp
Publisher : Bloomsbury Publishing
Page : 510 pages
File Size : 42,7 Mb
Release : 2019-11-28
Category : Law
ISBN : 9781509929467

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Form and Substance in the Law of Obligations by Andrew Robertson,James Goudkamp Pdf

This volume explores the relationship between form and substance in the law of obligations. It builds on the rich tradition of legal thought that deploys the concepts of form and substance to inform our understanding of the common law. The essays in this collection offer multiple conceptions of form and substance and cover an array of private law subjects, scholarly approaches and jurisdictions. The collection makes it clear that the interplay between form and substance is a key element of the dynamism that characterises this area of the law.

Author : Lawrence Zelenak
Publisher : Cambridge University Press
Page : 317 pages
File Size : 43,9 Mb
Release : 2018-01-11
Category : Business & Economics
ISBN : 9781108421508

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Figuring Out the Tax by Lawrence Zelenak Pdf

Recounts the forgotten early development of the federal income tax in the United States. Topics covered range from marriage, to capital losses, to withholding. This book will be of particular interest to tax academics and professionals, but also to anyone wondering how income tax achieved its current form.

Author : Reuven Shlomo Avi-Yonah,Nicola Sartori,Omri Marian
Publisher : Oxford University Press, USA
Page : 202 pages
File Size : 42,8 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 : Florian Haase,Georg Kofler
Publisher : Oxford University Press
Page : 1185 pages
File Size : 44,9 Mb
Release : 2023-09-22
Category : Law
ISBN : 9780192652331

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The Oxford Handbook of International Tax Law by Florian Haase,Georg Kofler Pdf

International Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape the international tax system. The Oxford Handbook of International Tax Law provides a comprehensive exploration of these key issues which will shape the future of tax law. Divided into eight parts, this handbook traces the history of international tax law from its earliest days until the present, including reflections on the developments that have characterized the last one hundred years. The second section places tax law within the broader international context considering how it relates to public and private international law, as well as corporate, trade, and criminal law. Sections three and four consider key legal principles and issues such as regional tax treaty models, OECD dispute resolution, and transfer pricing versus formulary apportionment. Subsequent analysis places these issues within their European and cross-border contexts providing an assessment of the role of the ECJ, state aid, and cross-border VAT. Section seven broadens the scope of this analysis, asking how trends in recent major economies and regions have helped shape the current outlook. The final section considers emerging issues and the future of international tax law. With over sixty authors from 28 different countries, the Oxford Handbook of International Tax Law is an invaluable resource for scholars, academics, and practitioners alike.