International Taxation of Trust Income

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International Taxation of Trust Income
Mark Brabazon, Mark Brabazon
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Last edited by MARC Bot
August 9, 2025 | History

International Taxation of Trust Income

  • 1 Want to read

"This book presents the principles and design of international taxation of trust income and distributions as a coherent subject of international tax law. It begins with the trust tax rules and international settings of four countries -- Australia, New Zealand, the United Kingdom and the United States -- focusing on the attribution of trust income to the grantor/settlor, the beneficiary or the trust entity, trust residence, and the taxation of trust distributions. Having identified the international taxing principles that those countries apply to trusts, it infers a range of principles and settings that may be applied by countries generally and examines how the interaction of those settings may lead to double- or non-taxation overall. Consideration is given to conflicts of attribution, hybridity and fiscally homeless trusts. The book examines the interaction of tax laws in non-treaty and treaty situations and puts these interactions in context as part of the broader international tax order and recommendations of the OECD/G20 BEPS project. It proposes an approach to tax design based on an ordered overview of different taxing claims and the interests which they represent, respect for the fiscal sovereignty of countries concerned, and recognition of the differing roles of national laws and tax treaties"--

Publish Date
Language
English
Pages
414

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Edition Availability
Cover of: International Taxation of Trust Income
International Taxation of Trust Income
2019, Cambridge University Press
in English
Cover of: International Taxation of Trust Income
International Taxation of Trust Income
2019, Cambridge University Press
in English
Cover of: International Taxation of Trust Income
International Taxation of Trust Income: Principles, Planning and Design
2019, Cambridge University Press
in English

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Book Details


Classifications

Library of Congress
K4536.T78B73 2019, K4536.T78 B73 2019

Edition Identifiers

Open Library
OL28715994M
ISBN 13
9781108492256
LCCN
2018058434
OCLC/WorldCat
1083182791

Work Identifiers

Work ID
OL21204651W

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