Die Unternehmensteuerreform 2008 zielt darauf ab, die Attraktivität des Standortes Deutschland und die unternehmerische Eigenkapitalausstattung zu verbessern. Dies soll durch Steuersatzsenkungen für Kapitalgesellschaften und die Einführung einer Thesaurierungsbegünstigung für...

In the current US tax system, capital gains are taxed at a lower rate than ordinary income. What does that mean for the sale of IP and intangible assets? Is it possible to convert ordinary income to capital gain by changing the form of the transaction? This article will address anomalies in the...

It has become conventional wisdom, based partly on postulated portfolio adjustments by investors in risky assets, (1) to view an income tax as equivalent to a tax levied only on the risk free return to capital and as therefore equivalent to a wealth tax; and (2) to view the difference between an...

Taking Singapore as an example, this article lays out a series of tests for determining whether gains arising from the disposal of cryptocurrencies are trade or business income, “all other income” or capital gains. It also considers the possibility of a presumption that individuals engaging...

In September of 2005, the Canadian government launched a consultation process with regard to the non-taxable status of income trusts. Less than two weeks later, they announced that the issuance of advance rulings with regard to the creation of new income trusts was being suspended. Although...

One of the main arguments against raising capital income tax rates is that doing so discourages savings and investment and hinders economic growth. However, academic research on taxes and growth suggests that this argument has no real basis. And the primary alternatives to capital income...

Out of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric and 59% are asymmetric, i.e., they prescribe different dividend withholding tax rates (WTRs) depending on the foreign investor's ownership fraction. The paper investigates the reasons for this phenomenon, namely why...

The merits of capital levies depend on the likelihood of repetition, the extent of anticipation, and its effects on distribution. The relevance of these features, which in varying degrees is underdeveloped or underappreciated in pertinent literatures, is elaborated and then considered with...

Originally published as Finance Act commentary in the British Tax Review this paper begins by briefly examining four technical changes to the UK EIS, SEIS and VCT venture capital tax reliefs made by the UK Finance Act 2016. Detailed consideration is then given to the implications that the UK...