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Author: Mark Brabazon Publisher: Cambridge University Press ISBN: 9781108729178 Category : Law Languages : en Pages : 0
Book Description
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.
Author: Mark Brabazon Publisher: Cambridge University Press ISBN: 9781108729178 Category : Law Languages : en Pages : 0
Book Description
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.
Author: Lee Hadnum Publisher: CreateSpace ISBN: 9781497381568 Category : Business & Economics Languages : en Pages : 308
Book Description
"An authoritative review of the topic" - The Times "A useful read" - Guardian Unlimited "A helpful guide to non-resident and offshore tax matters" - The Telegraph New March 2014 Edition - fully updated for the latest 2014/2015 changes including: The proposed changes to the CGT regime for non residents from April 2015 Latest changes to the statutory residence test for 2014 Recent decisions on residence Changes to Inheritance tax for non doms Changes announced in the March 2014 Budget Leaving the UK and becoming non UK resident offers many tax planning benefits. Non UK domiciliaries can also structure their affairs to avoid UK tax. This tax book is essential reading for: Anyone considering moving abroad to avoid income tax or CGT Anyone planning to work overseas Anyone returning to the UK after a period of non-residence Non UK domiciliaires planning to live in the UK tax efficiently What is Included in this book? Subjects covered include: Full and comprehensive explanation of how to establish non-domicile and non-residence. March 2014 Budget changes. How becoming non-resident could save you a fortune in tax. How the statutory residence test applies from April 2013. Detailed analysis of relevant cases on non residence. Exactly how to make a distinct break with UK to avoid UK residence. How to take advantage of loopholes in the Statutory Residence provisions. How HMRC keeps a track on UK visits with new technology. Whether you should or shouldn't be claiming the personal allowance after you leave the UK. How to make capital & income distributions from offshore trusts tax efficiently. Exactly how to establish company residence overseas. Detailed explanations of how to avoid UK tax on your income from rents, dividends, pensions and employment. How you could completely escape capital gains tax both in the UK and abroad. Pitfalls to negotiate when avoiding UK capital gains tax. How to protect property investments from the taxman. Tax implications of selling your UK home after you leave the UK. The latest non-dom tax changes for 2013. How to lose a UK domicile and how to retain an overseas domicile. How to avoid inheritance tax by losing your UK domicile. How to use your spouse to slash your tax bill. How the changes to the remittance basis will affect non UK domiciliaries AND the opportunities you still have to reduce UK taxes. How the £30,000 and £50,000 annual tax charge for non UK domiciliaries works. How to remit income and capital gains free of UK tax. How the new CGT regime for non-residents from April 2014 may apply. What you need to know about the new Business Investment Exemption. How foreign nationals can escape UK taxes altogether. Dedicated areas of advice for investors in overseas property. Changes to the treatment of loans for non-doms. How you could claim tax free lump sums whilst working abroad. How Double Tax Relief works and how to make the most of it. How to avoid tax everywhere by becoming a "Tax Nomad". Tax advantages and disadvantages of offshore trusts and companies. Detailed analysis of the 2013 changes to the tax treatment of offshore companies. A detailed look at when you can and can't use offshore companies and trusts to reduce UK taxes. How overseas investors should invest in UK property. How non UK domiciliaries can use excluded property trusts tax efficiently in 2014/2015. How to save tax with double tax treaties. and much more...
Author: Brigitte Alepin Publisher: Kluwer Law International B.V. ISBN: 9041194614 Category : Law Languages : en Pages : 229
Book Description
Over the past few decades, the concentration of wealth and property in the hands of a few has been facilitated by tax evasion, tax avoidance, and above all by tax competition. Fortunately, a determined move toward international cooperation among tax authorities is gathering its forces to do battle. This invaluable book shows how the globalization of trade, the digitization of the economy, tax competition between sovereign states, the erosion of the tax base, and the transfer of pro ts have all revealed the weaknesses of a traditional tax system that has reached its limits, and how numerous states and groups of states have joined efforts in creating a new international tax system designed to restore fairness and stability in the levying of taxes worldwide. Stemming from a 2016 conference initiated by the Canadian non-pro t organization TaxCOOP, convened by the World Bank and bringing together well-known taxation experts from prominent international organizations, the book presents outstanding contributions highlighting the impacts of tax competition and viable solutions. Among the issues and topics covered are the following: – electronic commerce and electronic money; – transfer pricing; – derivatives and hedge funds; – protecting tax whistle-blowers; – offshore tax investigations; – possibility of an international tax court; – impact of tax competition on developing countries; – carbon pricing; – tobacco taxation; and – effective taxation of the ultra-wealthy and their nancial capital. The chapters include details of country experiences and results, in some cases analyzed by key protagonists themselves. Collectively, the contributions take a giant step toward reinforcing the power of sovereign states in sectors such as the environment, education, and health. As an authoritative guide to increasing the level of transparency and accountability of private and public economic actors and restoring citizens’ trust in the fairness of our global governance systems, this peerless volume will be warmly welcomed by tax lawyers, taxation authorities, and interested academics worldwide.
Author: Emma Chamberlain Publisher: ISBN: 9780414043350 Category : Trusts and trustees Languages : en Pages : 1679
Book Description
Trust Taxation covers the taxation of UK resident and non-resident trusts explaining in detail the income tax, capital gains tax and inheritance tax treatment of the various different types of trusts. The book covers the tax consequences of creating and ending a trust, as well as the tax issues to consider during the lifetime of each type of trust and on distributions to beneficiaries. Part 1 contains an overview of trust law including recent case law on Hastings Bass, the categorisation of foreign entities, the new domicile and residence proposals and case law on residence and domicile generally. It also summaries the tax rules for foreign domiciliaries. Parts 2 to 4 explain the relevant legislation in detail as it relates to trusts, including discussion of entrepreneurs' relief, rollover relief, reservation of benefit, excluded property and relevant property trusts. Part 5 deals with special situations, including the family home, chattels, employee benefit trusts, pilot trusts, bare trusts, disabled trusts, will drafting, variations, business property relief and agricultural property relief, divorce and trusts.
Author: Rose-Marie Antoine Publisher: OUP Oxford ISBN: 9780199693450 Category : Law Languages : en Pages : 0
Book Description
This new edition of the leading comparative work on offshore financial law provides a fresh look at the current legal landscape in this sector offering guidance on complex legal issues and context for matters of practice.
Author: Raymond Adema Publisher: Kluwer Law International B.V. ISBN: 9041128395 Category : Law Languages : en Pages : 578
Book Description
This book examines the taxation of Undertakings for the Collective Investment in Transferable Securities (UCITS) in Austria, Germany, the Netherlands, and the United Kingdom. It analyses the tax consequences of the cross-border trade in units of UCITS for unitholders residing in the countries examined. It also features recommendations to remove the tax advantages and disadvantages that occur in cross-border trading.
Author: Alon Kaplan Publisher: ISBN: 9781911078081 Category : Trusts and trustees Languages : en Pages : 0
Book Description
The fourth edition features fully updated chapters plus new chapters on Jersey foundations, Quebec, Hong Kong, Singapore, Israel, what it means to be a fiduciary, Islamic (waqf) trusts, and trusts in relation to divorce, among others. The new edition, produced in association with STEP.
Author: Mark Brabazon
Author: Mark Brabazon
Author: Lee Hadnum
Author: Terry Neal
Author: United States. Department of the Treasury
Author: Brigitte Alepin
Author: Emma Chamberlain
Author: Rose-Marie Antoine
Author: Raymond Adema
Author: Alon Kaplan
Author: John Allsebrook Simon Simon (1st viscount)