Description: 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.
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EAN: 9781108492256
UPC: 9781108492256
ISBN: 9781108492256
MPN: N/A
Book Title: International Taxation of Trust Income: Principles
Number of Pages: 414 Pages
Language: English
Publication Name: International Taxation of Trust Income
Publisher: Cambridge University Press
Publication Year: 2019
Subject: Estates & Trusts, Taxation
Item Height: 0.9 in
Type: Textbook
Item Weight: 27.5 Oz
Item Length: 9.3 in
Author: Mark Brabazon
Subject Area: Law
Series: Cambridge Tax Law Ser.
Item Width: 6.1 in
Format: Hardcover
