In 1987, New Zealand taxpayers could avoid tax by establishing foreign corporations in which they held a controlling shareholding in low tax jurisdictions. This avoidance could occur in two ways. First, through using the foreign corporation to intercept passive income, such as interest or...

Introduction -- Beneficial Ownership : From Conscience to Liberalism and Law -- Beneficial Ownership in Tax Law -- From Domestic Tax Law to Tax Treaties : How Beneficial Ownership Jumped -- from US and UK Tax Treaty Policy into the Worldwide Tax Treaty Network -- Changing Skin in the OECD Model...