Inheritance tax on trusts

In addition to the extensive changes made by the Finance Act2006 to the inheritance tax rules on trusts, there is now afurther significant development. HM Revenue and Customs (HMRC)have recently responded to a number of questions raised by severalprofessional bodies including STEP (the Society of Trust andEstate Practitioners) and the CIOT (the Chartered Instituteof Taxation) on a number of detailed points on the new legislation.The responses from HMRC are very helpful and will clarify anumber of important matters, although there are a number ofissues that still need to be resolved. The main areas whichwere covered in the questions are outlined in this article.     

Is tax competition harmful and is the EU an optimal tax area?

This paper examines the issue of harmfulness of tax competition commenting on issues like welfare, growth, redistribution, harmonization and individual freedom. A simple game theoretical ap proach is formulated, where for the first time the two players start from unequal initial conditions, thus influencing strategy and outcomes. Next we propose the new criterion of Optimal Tax Area under which the possibility and feasibility of tax harmonization is examined. The policy implication of our paper is that we do not expect harmonization for direct taxes like corporate taxes in the EU in the near future and if so, harmonization of corporate tax rates on low levels. We conclude that both more theoretic research and empirical evidence are needed before we can answer with certainty whether tax competition is harmful or not. classification A1 . D6 . H0     

Serious tax fraud and noncompliance

Research Summary This article reviews what international evidence exists on the impact of civil and criminal sanctions upon serious tax noncompliance by individuals. This construct lacks sharp definitional boundaries but includes large tax fraud and large-scale evasion that are not dealt with as fraud. Although substantial research and theory have been developed on general tax evasion and compliance, their conclusions might not apply to large-scale intentional fraudsters. No scientifically defensible studies directly compared civil and criminal sanctions for tax fraud, although one U.S. study reported that significantly enhanced criminal sanctions have more effects than enhanced audit levels. Prosecution is public, whereas administrative penalties are confidential, and this fact encourages those caught to pay heavy penalties to avoid publicity, a criminal record, and imprisonment. Policy Implications Although it has yet to be proven that prosecution has a greater or lesser impact on these offenders, increased prosecution might be justified for purposes of moral retribution as well as perceived social fairness.     

税务行政复议范围的再认识

根据我国<行政复议法>有关行政复议范围的规定,纵观市场经济发展要求和现代各国行政立法情况,应对我国<税务行政复议规则>进行全面修改,确认全新的税务行政复议受案范围.     

现代税收文化的构建与完善

随着社会的进步和人类思想意识的高度理性,税收越来越民主,越来越显示出强烈的公共特性。与传统的税收文化相比,现代税收文化也呈现出进步性、复杂性、社会性、公共性的特征,这些特征要求我们积极构建适应时代要求的现代税收文化。     

Israeli legislation on aggressive tax planning

Israel's new law requiring taxpayers to report aggressive taxplanning arrangements to the Israeli Tax Authority requiresprofessionals to consider the reporting implications and therisks when advising clients.     

关于完善个人所得税法若干重大问题的法律思考

在西方市场经济国家，因个人所得税的主体税种地位及其与人民利益直接相关，个人所得税法的完善与否已被视为一国税制是否成熟的重要标尺之一。在我国，随着改革开放的实施与深入，《个人所得税法》得以于1980年9月颁行，其后又历经1993年10月、1999年8月两次修订，…….