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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 an
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.
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