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Preface | p. v |
Table of Cases | p. xv |
Introduction to Global Tax Systems and Income Taxes | p. 1 |
Introduction | p. 1 |
The Structure of Income Taxes | p. 4 |
The Nature of "Income" | p. 6 |
Commissioner of Taxation v. Cooke & Sherden | p. 8 |
Benefits in Kind | p. 18 |
Introduction | p. 18 |
Excerpt From the Report of the Royal Commission on Taxation | p. 18 |
Note | p. 20 |
Detchon v. Her Majesty the Queen | p. 20 |
Guay v. Her Majesty the Queen | p. 27 |
Note | p. 32 |
Taxation of Fringe Benefits | p. 32 |
Ruling 1999/6 | p. 34 |
Note | p. 39 |
Gifts and Inheritances | p. 43 |
Introduction | p. 43 |
Campbell v. Minister of National Revenue | p. 44 |
McMillan v. Minister of National Revenue | p. 49 |
Note | p. 51 |
Gifts as Realization Events | p. 52 |
Note | p. 53 |
The Queen v. Mastronardi | p. 56 |
Taxable Unit and Attribution of Income | p. 59 |
The Taxable Unit | p. 59 |
Family Allowances | p. 62 |
Income Splitting Rules | p. 62 |
Income Attribution in Canada | p. 63 |
Assignments Without the Transfer of Property | p. 64 |
It-335R2 | p. 65 |
Note | p. 68 |
Neuman v. Minister of National Revenue | p. 69 |
Note | p. 79 |
Overton v. Commissioner | p. 80 |
Note | p. 81 |
Ferrel v. Her Majesty the Queen | p. 82 |
Note | p. 90 |
Attribution of Income, Gain, or Loss in Connection With the Transfer of Property | p. 91 |
Deductions | p. 97 |
Introduction | p. 97 |
General Rules for Australian Tax Deductions | p. 99 |
Federal Commissioner of Taxation v. Snowden & Willson Proprietary Ltd. | p. 100 |
Softwood Pulp & Paper Ltd v. Commissioner of Taxation | p. 104 |
Note | p. 108 |
Interpretive Decision 2006/614 | p. 109 |
Morris v. Commissioner of Taxation | p. 110 |
Case 29/95 | p. 124 |
Note | p. 126 |
Charitable Deductions in Australia | p. 126 |
Interpretive Decision 2003/727 | p. 126 |
Interpretive Decision 2002/577 | p. 129 |
French Decisions | p. 130 |
Case N. 35 697 | p. 130 |
Note | p. 131 |
Decision of French Constitutional Council | p. 131 |
Note | p. 136 |
Taxation of Capital Gains and Losses | p. 137 |
Introduction | p. 137 |
The Californian Copper Syndicate v. The Inland Revenue | p. 137 |
Merchants' Loan & Trust Co. v. Smetanka | p. 140 |
Note | p. 145 |
Policy | p. 146 |
Blueprints for Basic Tax Reform | p. 147 |
Note | p. 151 |
The Tax Treatment of Capital Gains in Foreign Jurisdictions | p. 151 |
Note | p. 153 |
Income Tax Interpretation 120R6 | p. 154 |
Note | p. 159 |
Restrictions on Capital Losses | p. 159 |
International Income Taxation | p. 161 |
Introduction | p. 161 |
Cook v. Tait | p. 161 |
Note | p. 164 |
An Overview of United States International Taxation | p. 165 |
Revenue Ruling 69-630 | p. 170 |
Note | p. 171 |
Johansson v. United States | p. 172 |
Simenon v. Commissioner | p. 176 |
International Taxation in Foreign Tax Systems | p. 180 |
Excerpt From the Impact of International Tax Reform: Background and Selected Issues Relating to U.S. International Tax Rules and the Competitiveness of U.S. Business pp. 32-54 | p. 180 |
Index | p. 197 |
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The Used, Rental and eBook copies of this book are not guaranteed to include any supplemental materials. Typically, only the book itself is included. This is true even if the title states it includes any access cards, study guides, lab manuals, CDs, etc.