Comparison And Assessment Of The Tax Treatment Of Foreign Source Income In Canada Australia France Germany And The United States

The report deals with selected aspects of the tax treatment of foreign-source income in Canada, Australia, France, Germany and the US. It emphasizes the structural features of each country's tax system with respect to the taxation of foreign-source income derived by resident corporations. In particular, the report focuses on the taxation of dividends from foreign corporations, controlled foreign corporation (CFC) rules, foreign investment funds rules, and source of income and expense rules.

A debate is underway about how the U.S. should tax foreign-source, corp. income. Currently, the U.S. allows domestic corp. to defer tax on the earnings of their foreign subsidiaries and also gives credits for foreign taxes paid, while most other developed countries exempt the active earnings of their multinational corp. foreign subsidiaries from domestic tax. This report describes for a group of study countries with exemption systems: (1) the rules for exempting foreign-source income; and (2) the compliance risk and taxpayer compliance burden, such as recordkeeping, of the rules. The countries selected are Australia, Canada, France, Germany, and the Netherlands. Charts and tables.

In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.

This 1997 edition of OECD's periodic surveys of Canada's economy examines recent economic developments, policies and prospects. It includes a special feature on the tax system.

Marginal income tax rates in advanced industrial countries have fallen dramatically since the mid-1980s, but levels and progressivity of income taxation continue to differ strongly across countries. This study offers a new perspective on both observations. It blends theoretical inquiry with focused quantitative analysis and in-depth investigation of seven countries: Germany, Australia and New Zealand as well as Denmark, Finland, Norway and Sweden. The Politics of Income Taxation highlights the equity-efficiency tradeoffs that structure the politics of income taxation, and analyses how income taxes are embedded in broader tax systems. It explains the limited but enduring importance of political parties and democratic institutions. Finally, the study paints a nuanced picture of the role of globalisation and thus sheds light on the pros and cons of tax coordination at European and international levels.

Comparative Income Taxation A Structural Analysis Fourth Edition 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 three previous editions and now thoroughly updated to encompass the latest changes and trends. In it, leading authorities from eleven of the world’s most important national taxation systems each contribute their particular expertise to a study of specific crucial problems of tax design. In addition to the nine countries covered in previous editions—Australia, Canada, France, Germany, Japan, the Netherlands, Sweden, the United Kingdom and the United States—China and India have now been added to provide the perspective of developing countries. Individually authored country descriptions outline the climate and institutional framework in which each of the eleven national taxation systems’ substantive 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 effect of tax treaties. Several new topics—including the classification of employees and independent contractors, the taxation of pensions, patent box regimes, the taxation of indirect transfers and the tax challenges of the digital economy—have been added. Especially timely are discussions of changes stemming from the G20/OECD Base Erosion and Profit Shifting project. The introduction has also been expanded to include a new section on European Union (EU) law as it affects the tax laws of EU Member States. This new edition of a classic source of information and analysis for students, professors, researchers, tax practitioners and tax policy officials on the different ways that countries design their income tax systems will be widely welcomed by the international tax community.