Comparative Income Taxation : A Structural Analysis

Comparative Income Taxation

A Structural Analysis

Fifth Edition

Edited by Hugh J. Ault, Brian J. Arnold & Graeme S. Cooper

In complex national income tax systems, structural and design variations from one country to another present major obstacles to the kind of comparative understanding that economic globalization requires-hence, the great significance of this outstanding book, highly acclaimed through four previous editions and now thoroughly updated to encompass the latest changes and trends. In it, leading authorities from 11 of the world's most important national taxation systems-Australia, Canada, China, France, Germany, India, Japan, The Netherlands, Sweden, the United Kingdom and the United States-each contribute their particular expertise to a study of major structural issues of income tax design.

Individually authored country descriptions outline the climate and institutional framework in which each of the 11 national taxation systems' substantive tax rules operate. All the country descriptions are analyzed in accordance with a common format to facilitate comparisons of the ways in which the countries' tax systems are similar and in which they differ. They form the background to an expertly informed comparative analysis focusing on three major areas: basic income taxation, taxation of business organizations and international taxation. Most of the rules especially important for international business and investment are dealt with here, including (among many others) rules on the following:

• classification of business entities;

• taxation of corporations and their shareholders;

• corporate organization and restructuring;

• taxation of partnerships;

• residence and source taxation;

• controlled foreign company rules;

• restrictions on the deduction of interest;

• courts dealing with tax matters; and

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