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Taxation of Trusts
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TL;DR: Hill et al. as discussed by the authors explored various principles of taxing trusts under the Land and Income Tax Act 1956 and analyzed the requirements of Section 155(a) and 155(b) of the Act and the facilitation of income splitting, before turning to consider the shortcomings of section 84A as a plug to the gap of created by the child exemption in personal taxation.
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Abstract: With acknowledgment of the growing popularity of the trust as an effective taxation planning vehicle, this article explores various principles of taxing trusts under the Land and Income Tax Act 1956 The author first analyses the requirements of sections 155(a) and 155(b) of the Act and the facilitation of income splitting, before turning to consider the shortcomings of section 84A as a plug to the gap of created by the child exemption in personal taxation The article next considers the application of section 105 to short-term or revocable trusts Lastly, the article considers general points of settlement of personal income by trust, and the use of trusts for this purpose in light of the general anti-avoidance provision contained in section 108 Abstract by Holly Hill
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Citations
International Taxation of Trust Income: Principles, Planning and Design
Mark Brabazon
- 30 Apr 2019
TL;DR: In this paper, Brabazon established the study of international taxation of trust income as a globally coherent subject and identified a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust.
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•Dissertation
L'instrumentalisation fiscale du droit de propriété
Guillaume Bzowski
- 30 Jun 2011
TL;DR: In this article, a taxonomy of the elements of the instrumentalisation fiscale of the droit de propriete is presented, with respect to the consequences fiscales of an operation juridique that is fondant sur l’instrumentalisation du droit of propriete.
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