International Taxation of Trust Income

ISBN: 9781108680516 出版年：2019 页码：418 Mark Brabazon Cambridge University Press

In爄nternational 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 u.K., and the u.S., 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.