Comparative Income Taxation, a Structural Analysis

The comparative study of income taxation provides fresh perspectives from which to examine and evaluate a particular national system. Comparative Income Taxation presents a comparative study of different solutions adopted by nine industrialized nations to the common problems of income tax design. In this informative work, a distinguished group of tax experts examines the treatment of important structural issues such as taxation of fringe benefits, child care deductions, taxation of disputed income, and the classification of business entities in their national systems. The study covers Australia, Canada, France, Germany, Japan, the Netherlands, Sweden, the United Kingdom, and the United States. Comparative Income Taxation comprises several parts: + Part One presents individual country descriptions outlining how each system developed its own set of approaches and principles; + Part Two deals with basic income taxation, + Part Three covers taxation of business organisations, + Part Four addresses international taxation, and + Part Five concludes the study with a detailed bibliography. Within each part, the subparts and sections outline various structural issues or problems which have arisen in the area under consideration. The author describes the countries-- responses to the problems with a view toward identifying common patterns or approaches and highlighting unique or interesting solutions. This innovative work provides a comprehensive introduction to foreign approaches to income taxation for academics, practitioners, and policymakers.

Business & Money

Brian J. Arnold

Hugh J. Ault

AULT

Economics

Springer

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.

Comparative Income Taxation, A Structural Analysis, 3rd Edition Revised

Legal Theory & Systems

Kluwer Law International

About this book: International Tax Primer provides an accessible and comprehensive guide to the fundamental aspects of international taxation with an introduction to the policies that countries seek to advance with their international tax rules. Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition nearly two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fourth edition follows the format and sequence of earlier editions but adds details on ongoing developments surrounding the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting (BEPS) project, updates to the OECD and UN Model Conventions, the 2017 US tax reform, the EU anti-tax avoidance directive and continuing issues concerning the digital economy. What’s in this book: The book strikes a balance between the specific and the general by illustrating the fundamental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following with an extensive glossary of international tax terms: <ul>
<li>role of the tax adviser in planning international transactions;</li> <li>taxation of residents on foreign income and of nonresidents on domestic income;</li> <li>mechanisms used to mitigate the risks to taxpayers of international double taxation;</li> <li>transfer pricing rules to prevent the avoidance of tax by multinational corporations;</li> <li>anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities;</li> <li>overview and analysis of the provisions of bilateral tax treaties and the OECD and UN Model Treaties on which they are generally based; and</li> <li>challenges posed by taxation of income derived from the digital economy.</li> </ul>
How this will help you: With examples of typical international tax planning techniques and descriptions of the work of the major international organizations that play an important role with respect to international tax, the Primer remains the preeminent first recourse for professionals in the field. Although of greatest value to students, tax practitioners and government officials confronting international tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis. The Primer provides the reader an easy-to-read understanding of the basic concepts and structural features of international taxation that form the basis for all countries’ international tax rules obtaining an understanding of the tax policy principles underlying the international tax system.

International Tax Primer

Wolters Kluwer

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.

Comparative Income Taxation: A Structural Analysis

Graeme Cooper

Business

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