International Taxation of Trust Income - Principles, Planning and Design (Paperback)

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.

General

Imprint:	Cambridge UniversityPress
Country of origin:	United Kingdom
Series:	Cambridge Tax Law Series
Release date:	June 2022
Authors:	Mark Brabazon
Dimensions:	229 x 152 x 22mm (L x W x T)
Format:	Paperback - Trade
Pages:	415
ISBN-13:	978-1-108-72917-8
Categories:	Books > Law > Other areas of law > Military law & courts martial Books > Law > Laws of other jurisdictions & general law > Constitutional & administrative law > General Books > Law > Laws of other jurisdictions & general law > Financial, taxation, commercial, industrial law > Financial law > Taxation law
LSN:	1-108-72917-7
Barcode:	9781108729178

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