This seminar focused not only on the technical consideration of secondary aspects but also on the underlying philosophical question: namely, should secondary adjustments be employed at all and, if so, what are the appropriate limitations on their use? While a "corresponding adjustment" may be appropriate in order to avoid double taxation, other secondary adjustments, such as "conforming adjustments" and "reclassification of income" are more problematic. The panellists and audience were asked to consider the implications of secondary adjustments in the context of tax compliance, tax administration, and private contracts. Is it appropriate for the tax administrator to intervene in private transactions to the extent of "deeming" a capital contribution or "deeming" a dividend? Set-offs and corresponding adjustments, as well as about secondary adjustments, such as reclassification of income, are included here. Following the outline are examples and diagrams that explicate the principles explained in the outline, as well as papers prepared by individual panellists.

The distribution of taxes over different income groups, has, rightly or wrongly, assumed a central position in tax policy decisions. All serious tax proposals are now accompanied by tables illustrating this distribution. This volume shows how the accuracy of these tables can be improved.

The question of whether there are internationally recognized anti-avoidance rules that are applied to tax treaties involves two subsidiary questions: whether international law recognizes the concept of abuse of rights, and whether this concept of abuse of rights can be applied to tax treaties. The book then turns to the question of whether provisions included in the tax code that are expressly designed to re-characterize or deal with transactions that are considered to result in unacceptable avoidance of tax under the code can be extended and applied where there is an unacceptable avoidance of tax by virtue of the application of a tax treaty provision.

This guide breaks down the type of income to be taxed into the main categories which are treated in different ways under the Treaty. The major areas covered are: pure or passive income, i.e. investment income where the recipient does not earn by the provision of goods or services; income derived from independent activities, such as trading or professional activities by individuals, partnerships and companies; and the activities of sportsmen and entertainers. The book also deals with activities in which an individual is bound more closely to a particular company employer or former employer, thus covering income from employment, directorships or pensions. Each section is cross-referenced to the relevant Treaty articles and three appendices list the forms needed to make claims under the Treaty, and give the text of the Treaty in both English and German. The book should be a useful reference source for tax advisers, professionals and management involved in international structures, tax planning and advice, both in Germany and the UK, and throughout the world.

This volume provides a practical, basic introduction to the tax consequences faced by individuals residing and/or working in a foreign jurisdiction. Written for chief executive officers, directors of human resources, tax advisers and individuals involved in or contemplating an international residence or position, this reference can help lessen the "tax anxiety" of a foreign assignment. The national tax structure of over 30 nations are analyzed to identify planning opportunities, point out possible pitfalls and provide information on what tax liabilities expatriates can expect.

This is a study of the income tax treatment of fringe benefits. In the first half, a review is given of the theories underlying different fringe benefit income tax rules and the conceptual rules that arise with respect to particular types of benefits. In the second part, a look is taken at the actual rules governing the tax treatment of fringe benefits in the following selected jurisdictions: Argentina, Australia, Austria, Belgium, Brunei, Canada, Denmark, France, Germany, Hong Kong, India, Ireland, Japan, Korea, Luxembourg, Mexico, Netherlands, New Zealand, Norway, Pakistan, Paraguay, Singapore, Spain, Switzerland, and the United Kingdom.

A tax expenditure is a 'tax break' allowed to a taxpayer or group of taxpayers, for example, by way of concession, deduction, deferral or exemption. The tax expenditure concept, as it was first identified, was designed to demonstrate the similarity between direct government spending on the one hand and spending through the tax system on the other. The identification of benefits provided through the tax system as tax expenditures allows analysts to consider the fiscal significance of those parts of the tax system which do not contribute to the primary purpose of raising revenue. Although a seemingly simple concept, it has generated a range of complex definitional and practical issues, and this book identifies and critically assesses the controversial aspects of tax expenditure and tax expenditure management.

"In the United States, proposals for gasoline tax hikes have consistently met with broad-based congressional opposition. Although such taxes are a common and effective method of conserving energy in other industrialized nations, U.S. policy has traditionally relied on regulatory programs rather than fuel taxes to promote energy efficiency in automotive transportation. This book examines both the political causes and the economic effects of this idiosyncratic policy preference. Moderating the consumption and importation of oil has been an explicit goal of the United States over the past twenty years. Pietro S. Nivola and Robert W. Crandall argue that a higher levy on gasoline would be a more efficient way of achieving this goal than current automotive fuel economy standards. In fact, they find that an additional excise of less than twenty-five cents per gallon over the past dozen years would have conserved more oil than has the existing policy of administering gas mileage requirements for new passenger vehicles. And such a tax, they maintain, would not be as detrimental to the economy as opponents fear, nor as regressive as they claim. Why, then, is there such a strong national resistance to a fuel tax in the United States? And why is there less resistance in other countries? The authors examine the development of motor-fuel excises in Great Britain, France, Germany, Japan, and Canada, and explain the historical and political factors that have led to different national policy orientations. Turning their attention back to the United States, Nivola and Crandall show how regulatory measures have fallen short of their goal and why political barriers to bolder taxation of gasoline remain formidable. They conclude by offering suggestions for new directions in U.S. energy policy at the federal, state, and local level. "

This survey was initiated by a joint effort of the OECD and the Lincoln Institute of Land Policy, with the support of the International Association of Assessing Officers. The survey has the two-fold purpose of providing a concise introduction to property taxation in 14 countries, as well as presenting a comparative analysis of the major features of property taxes in these diverse jurisdictions.

An overview of the fiscal aspects in connection with the increasing economic and monetary integration within the EC. The harmonization of both indirect and direct taxes is discussed in depth while relevant historical developments are also highlighted. Attention is paid to the harmonization process in a number of areas that interface with tax law, in particular, social security law, parts of corporate law and the law on annual statements of accounts.

Die vorliegende Arbeit ist wahrend meiner Tatigkeit als wissenschaftlicher Mitarbeiter bei Prof. Dr. Heinz-Dieter Wenzel am Lehrstuhl fur Volkswirt- schaftslehre, insbesondere Finanzwissenschaft der Universitat Bamberg ent- standen und an der Universitat Bamberg als Dissertation angenommen wor- den. Fur die Betreuung der Arbeit durch Herrn Prof. Dr. Heinz-Dieter Wenzel moechte ich an dieser Stelle herzlich Dank sagen. Mein Dank gilt ebenso Herrn Prof. Dr. Ulrich Meyer, der als zweiter Gutachter durch hilfreiche Anregungen zum Gelingen der Arbeit beitrug. In einem kollegialen Klima der gegenseitigen Unterstutzung gedeiht wissen- schaftliche Arbeit am besten. Meinen Kollegen Herrn Dr. Martin Arnold und Frau Dipl.-Volkswirtin Barbara Wolfe moechte ich Dank aussprechen fur ihre Bereitschaft, sich wahrend des gesamten Entstehungsprozesses der Arbeit mit den von mir zu Papier gebrachten Ideen in Inhalt und Form auseinanderzusetzen. Besonderen Dank schulde ich Herrn Dr. Kai Konrad und meinem Bruder, Herrn Dipl.-Mathematiker Ingo Wrede, die zu einzelnen Aspekten der The- matik ausserst wertvolle Hinweise gaben. Frau Andrea Woelfe! und Herrn Michael Betten, die durch sorgfaltiges Durcharbeiten des Manuskriptes manchen Fehler auszumerzen halfen, danke ich hierfur. Mein innigster Dank aber gilt meiner Frau, Frau Dipl.-Volkswirtin Christi- ane Wrede, die mir nicht nur durch kritische Lekture zahlreicher Entwurfe geholfen hat. Ihr Verstandnis und ihre Unterstutzung gestatteten es, mir die erforderliche Zeit zur Fertigstellung der Arbeit zu nehmen.

This volume explains the complexity of the US tax system, often by comparison and contrast with European and other national tax systems. Use of highly technical language is avoided in consideration of those readers for whom English is their second language. Sufficient detail is incorporated to answer most primary questions about what makes the US tax system work. Topics covered include individual and corporate income taxes, partnership taxation, special types of taxpayers (pensions, corporations) and the underlying "unwritten law" of US taxation. Special emphasis is placed on international rules, particularly inbound business, sales and investment. Broad coverage is given to anti-avoidance rules which contribute to the US tax system's complexity. References to the Internal Revenue Code, Treasury Regulations, major rulings and cases are also included.

Debates about tax policy arise every year in Washington, and legislative changes occur almost as often. In just the past decade, corporate tax burdens were dramatically reduced and then subsequently increased. But who really bears the burden of taxation? Finding a satisfactory way to address this question remains one of the biggest challenges for economists. While much research has explored this issue using annual data on household incomes and expenditures, this book considers the multiple effects of taxes on individuals over their entire lifetimes.

Since annual incomes typically vary from year to year, and change systematically over the course of a lifetime, annual income is not necessarily a good indicator of a person's relative well-being. Instead, Dianne Rogers and Don Fullerton categorize individuals into lifetime income groups, and re-estimate the pattern of earnings over the lifetime of each group. They utilize a general equilibrium model that encompasses household demands, work effort, and savings, and they calculate the distribution of each current tax. Because their model includes all major U.S. federal, state, and local taxes, it can be used to simulate the effects of changes in any of those taxes on investment, productivity, resource allocation, and the distribution of burdens.

Don Fullerton is professor of economics at the University of Virginia and visiting professor of economics and public policy at Carnegie Mellon, School of Urban and Public Affairs. He served as Deputy Assistant Secretary of the Treasury for Tax Analysis from 1985 to 1987. Diane Lim Rogers is assistant professor of economics at Pennsylvania State University.