The proper tax base : structural fairness from an international and comparative perspective : essays in honor of Paul McDaniel

著者

    • Brauner, Yariv
    • McMahon, Martin James, Jr.

書誌事項

The proper tax base : structural fairness from an international and comparative perspective : essays in honor of Paul McDaniel

edited by Yariv Brauner, Martin James McMahon, Jr

(Series on international taxation, v. 39)

Kluwer Law International, c2012

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内容説明・目次

内容説明

Virtually all objections to taxation schemes spring from perceptions of unfairness. Is tax fairness possible? The question is certainly worth investigating in depth, and that is the purpose of this book. Today, as governments are busily making new tax rules in the wake of staggering budget deficits, is perhaps an appropriate time to pay heed to fairness so it can be incorporated as far as possible into tax reform. With twelve contributions from some of the world's most respected international tax experts - including the late Paul McDaniel, in whose honor these essays were assembled - this invaluable book focuses on tax expenditure analysis, the quest for a just income tax, and division and/or harmonization of the income tax base among jurisdictions. Among the areas of taxation ripe for reform from a fairness point of view the authors single out the following: tax expenditure budget construction; tax expenditure reporting; modern welfare economics as a driver of tax reform; grantor trust rules; the notion of "horizontal equity"; the international tax norm of "income source"; transfer pricing; and jurisdictional application of VAT. Specific ongoing reforms in the United States, Australia, and other countries - as well a detailed analysis of the EU's proposed common consolidated corporate tax base (CCCTB) - are also examined for fairness.

目次

Preface. Part I Tax Expenditures. Chapter 1 The Staff of the Joint Committee on Taxation Revision of Tax Expenditure Classification Methodology: What Is To Be Made of a Change That Makes No Changes? Paul R. McDaniel. Chapter 2 Taxing Tax Expenditures? Martin J. McMahon, Jr. Chapter 3 The Tax Expenditure Concept Globally Miranda Stewart. Chapter 4 Tax Reform and Tax Expenditures in Australia Richard J. Vann. Chapter 5 Tax Reform Paul McDaniel Style: The Repeal of the Grantor Trust Rules Laura E. Cunningham & Noel B. Cunningham. Part II The Fair Tax Base and International Tax Reform. Chapter 6 Horizontal Equity Revisited James Repetti & Diane Ring. Chapter 7 What Is This Thing Called Source? Lawrence Lokken. Chapter 8 Formula Based Transfer Pricing Yariv Brauner. Part III A Comparative Perspective Chapter 9 The EU proposed CCCTB - Some Tax Treaty Issues Kees van Raad. Chapter 10 Shared Legal Orders: Some Thoughts about the Influence of EU Case Law on International Tax Law Rules of the EU Member States Irene J.J. Burgers. Chapter 11 Intra Group Loans - A Swedish Perspective Bertil Wiman. Chapter 12 European VAT and Jurisdiction to Tax Antonio Vazquez del Rey.

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