A report on a conference organised jointly by the Institute of Policy Studies, Wellington, the Asian Pacific Tax and Investment Centre, Singapore, and the Australian Tax Research Foundation, Sydney. The purpose was to study judicial and legislative anti-avoidance measures and treaty policies in...

This document is the final report of the Consultative Committee on Full Imputation and International Tax Reform. This final report outlines the Committee's recommendations on the outstanding issues relating to both sets of reforms. It explains the policy behind draft legislation produced by the...

We present four important dimensions to international tax policy from a tax-systems perspective, stressing that non-rate/base tax policies can have different cross-jurisdictional spillover effects than changes in tax rates. The dimensions are the allocation of global income among taxing...

This paper was presented as part of a workshop to supply chain managers in 2006, on tax planning as part of a tax risk management process. The paper contains useful tools to conduct the appropriate tax risk management strategy, with tax planning as the focal point. The paper also deals...

This article considers the significance of the term "beneficial ownership" in Articles 10, 11 and 12 of the OECD Model Double Tax Convention (“the Model”), and looks at features of commonly used cross-border structures (structured finance and holding companies) by way of practical background...

This paper summarizes the key features of tax risk management and sets out the typical steps that should be followed. It follows a typical Six Sigma process in going about tax risk management. This paper discusses tax risk management, in particular, in the context of Section 404 of the U.S....

Single-owner grantor trusts arise frequently in cross-border settings. Despite some resemblance to wholly-owned disregarded entities, their treatment could differ significantly for federal income tax purposes. In this report, Zhu sorts through some of these differences under the entity...

Taxation has become an indispensable part of modern economic systems worldwide, and there are a wide variety of different tax models with different policies, regulations, and collection systems that governments can choose from. Nations have realized the need to exercise care and caution in...

Much has been said and written about the ‘fiscal behaviour' of multinationals. A tax code of conduct is often mentioned as a 'catch-all solution' for stimulating 'acceptable fiscal behaviour'. Stakeholders increasingly demand fiscal accountability to obtain verifiable and validated credible...