Open Access. Powered by Scholars. Published by Universities.®
- Publication
- Publication Type
Articles 1 - 2 of 2
Full-Text Articles in Law
Introduction, Comparative Income Taxation: A Structured Analysis, Hugh J. Ault, Brian J. Arnold
Introduction, Comparative Income Taxation: A Structured Analysis, Hugh J. Ault, Brian J. Arnold
Hugh J. Ault
This work presents a comparative analysis of some of the structural and design issues which are involved in mature income tax systems. Countries selected for the study are Australia, Canada, France, Germany, Japan, The Netherlands, Sweden, the United Kingdom and the United States. Each of the systems has evolved its own particular set of approaches and principles, outlined in Part One. Ensuing Parts deal with Basic Income Taxation, Taxation of Business Organizations and International Taxation. There is much to learn in the tax field from a comparative analysis of common problems. One need not believe in the existence of a …
Reconsidering International Tax Neutrality, Michael S. Knoll
Reconsidering International Tax Neutrality, Michael S. Knoll
All Faculty Scholarship
For decades, U.S. international tax policy has shifted back and forth between territorial-source-exemption taxation and worldwide-residence-credit taxation. The former is generally associated with capital import neutrality (CIN) and the latter with capital export neutrality (CEN). One reason why national tax policy has shifted back and forth between those benchmarks is because it is widely accepted that a tax system cannot simultaneously satisfy both CEN and CIN unless tax rates on capital are harmonized across jurisdictions. In this essay, I argue that the international tax literature contains two different and conflicting definitions for CIN. Under one definition, which goes back at …