International Taxation of Trust Income: Principles, Planning and Design

Taxation

International Taxation of Trust Income: Principles, Planning and Design

By Mark Brabazon
Cambridge University Press June 2022

Specifications

ISBN-13
9781108729178
Publisher
Cambridge University Press
Publication
June 2022
Format
Paperback
Jurisdiction
U.K. ? Countri(es) for reference only

Also available as

Hardback

Details

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.

Table of Contents

Figures
Tables
Preface
Cases
Statutes
Other authorities
Treaties
Abbreviations
Glossary
1. Introduction
Part I. National Tax Laws:
2. The grantor
3. The beneficiary
4. The trust
5. Distributions
6. International taxation
Part II. Global Taxation:
7. The international tax order and the interaction of tax laws
8. Treaties
9. Conclusions and proposals – taxing the shadow
10. Appendix: detail of beneficiary attribution and taxation 389
Bibliography
Index
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