Australian income tax law provides taxpayers making donations to charities with a deduction for the amount of the donations. It also provides public benevolent institutions with an exemption from income taxation for income derived by way of gift or from the investment of donated funds. The...

The issues raised by VAT and financial investments may be the most challenging of all VAT and financial supplies to resolve. In a model VAT, there would be full recovery of all VAT associated with savings and investment. Three problems make it difficult to achieve this aim in respect of...

This paper reviews the income tax model included in the Basic World Tax Code (BWTC) in light of the risk of U.S. tax parochialism by designers. It considers the model in light of specific issues in respect of the measures dealing with income, deductions, the tax unit, company and shareholder...

This paper provides an overview and assessment of alternative methods of taxing capital income. We begin by considering why, and to what extent, capital income should be taxed. Having established a reasonably robust case for such taxation, we then review the difficulties of taxing capital income...

In this article, the authors examine a European Commission ruling that classified the U.K. controlled foreign corporation group financing exemptions as illegal state aid and has now been upheld by the General Court of the European Union. They argue that unlike the commission’s previous state...

Drafted prior to the adoption of capital gains tax in Australia, this paper sets out the key structural issues to be addressed in the design of a capital gains tax. In each case it considers options and indicates a preferred choice. Topics covered include the type of receipts that should be...

This paper explores the question whether entering into double tax treaties leads to more foreign investment. The topic has been the subject of a number of studies that have generated inconsistent results. The paper reviews previous studies and notes the limitations that may have affected their...

This chapter examines the historical development of the formulary apportionment approach in key jurisdictions.From the time income taxes were first widely enacted, tax designers have been concerned with the question of how to allocate profits in transactions that incorporated labour, capital or...