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

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

Wolters Kluwer

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