| Preface | viii |
| |
| - References
| xiv |
| - Acknowledgements
| xv |
| Chapter 1 | Introduction | 1 |
| |
| Chapter 2 | Illustrating how investing worldwide need not be affected by income taxation | 7 |
| |
| - Jim considers investing directly into local widget production
| 8 |
| - Jim considers investing in local widget production indirectly via a local company
| 13 |
| - Jim, Francis and Raymond consider investing in widget production involving international flows
| 17 |
| - Income taxation design has been moving towards the neutral ideal
| 23 |
| |
| Chapter 3 | Explaining concepts underpinning neutral taxation of investment income | 25 |
| |
| - Searching for neutral income tax design
| 26 |
| - Neutral income tax design applicable to all Jim’s investments
| 38 |
| - … if actual income is measured in nominal terms
| 39 |
| - … if income is measured in real terms
| 41 |
| - … and once investment risk is recognised
| 43 |
| |
| Chapter 4 | Putting the neutral income tax base into practice | 49 |
| |
| - Principled specification of taxable income
| 50 |
| - Design template accommodates tax values of all types of assets and liabilities
| 53 |
| - Design template has a range of practical advantages
| 54 |
| - Design template matches changes in tax value and actual value over period assets are held
| 55 |
| - Depreciating tangible assets
| 56 |
| - Appreciating assets and capital gains taxation
| 68 |
| - Delayed-cashflow assets
| 84 |
| - Rental property and negative gearing
| 94 |
| - Financial assets and liabilities (including leases and rights)
| 106 |
| - Leasing
| 128 |
| - Capital repayment assignment
| 141 |
| - Foreign bonds and bank accounts
| 145 |
| - Trading stock
| 154 |
| - What investments does Jim choose?
| 158 |
| |
| Chapter 5 | Integrating the local income of entities into investors’ tax assessments | 160 |
| |
| - Current varied entity income tax design
| 163 |
| - Widget production via a company
| 167 |
| - Widget production via a fixed trust
| 195 |
| - Widget production via a discretionary trust
| 207 |
| - Jim’s feelings about the taxation of entities
| 209 |
| - Consistent entity income tax design
| 210 |
| - Inquiry’s design to integrate entity taxable income with investors’ personal tax assessments
| 212 |
| - Practicalities of integrating taxable income of entities
| 231 |
| - Refunds to non-residents of domestic tax withheld
| 232 |
| - Measure of entity income to be taxed to entity investors
| 233 |
| - Entity distribution notices, chains of entities and assessment lags
| 234 |
| - Potential loss in tax revenue
| 236 |
| - Non-resident entity investors or beneficiaries
| 238 |
| - Information in entity distribution statements
| 239 |
| - Tax policy advisors’ overview
| 240 |
| - Case study: off-market and on-market share buy-backs
| 241 |
| - Off-market share buy-backs: tax treatment
| 242 |
| - On-market share buy-backs: tax treatment
| 250 |
| - Buy-back of entity interests under integration of entity income
| 256 |
| |
| Chapter 6 | Integrating foreign income into investors’ tax assessments | 258 |
| |
| - Taxing international investment flows to achieve neutral effect on investment decisions
| 258 |
| - Practical foreign tax crediting issues
| 261 |
| - Flow-through of foreign tax credits: offshore investment case study
| 264 |
| - Simplicity policy option
| 270 |
| - Complexity policy option
| 277 |
| - Compromise policy option
| 281 |
| - Integrating taxable income of entities in the international scene
| 285 |
| - Approaching ‘bliss point’ of investment income taxation
| 289 |
| |
| Annotated contents | 297 |
| |