International Taxation of Trust Income

Principles, Planning and Design

Mark Brabazon

• Publisher: Cambridge University Press
• Year: 2019
• Print ISBN: 9781108492256
• eBook ISBN: 9781108680516
• Topic: Diritto
• Subtopic: Diritto tributario

InInternational 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.

Table of contents

• Cover
• Half-title
• Series information
• Title page
• Copyright information
• Dedication
• Contents
• List of Figures
• List of Tables
• Preface
• Glossary
• List of Abbreviations
• Table of Cases
• Table of Statutes
• Other Authorities
• List of Treaties
• 1 Introduction
• Part I National Tax Laws: Australia, New Zealand, the United Kingdom and the United States
• Part II Global Taxation
• Appendix Detail of Beneficiary Attribution and Taxation
• Bibliography
• Index