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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.
"... provides detailed coverage of the rules governing the income taxation of estates, trusts, and their beneficiaries"--Page iii.
Explanation and comments upon the U.S. tax and reporting rules applicable to foreign trusts. Examples of suggested courses of action for common problems are given throughout.
Vol. 3 also issed as rev. 3rd ed. ; rev. 3rd edition of other vols. not planned.
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