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Type: Journal Articles Authors: Richard Wood ISSN: Print: 0143-5671 Online: 1475-5890
Published in: Fiscal Studies, Vol. 27, No. 2, June 2006
Volume, issue, pages: Vol. 27, No. 2, pp. 127-155
This paper suggests a relatively simple analytical framework for taxing all financial arrangements. The debt/equity distinction is determined by the contingency principle. The accruals/realisation distinction is determined separately by the volatility principle. The capital/revenue character distinction is effectively removed directly or by a character hedging regime. Hybrids, synthetics, hedging arrangements and other portfolios are tax-assessed on an aggregate, rather than a bifurcated, basis. The framework could be applied to both classical and dividend-imputation-based business tax systems. Search |
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