International Taxation of Trust Income

InInternational 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.