The Resource Beyond 'legal personality': private foundations as 'tax subjects'

Beyond 'legal personality': private foundations as 'tax subjects'

Label
Beyond 'legal personality': private foundations as 'tax subjects'
Title
Beyond 'legal personality': private foundations as 'tax subjects'
Creator
Subject
Language
eng
Summary
The tax treatment of private foundations does not directly follow from their incorporated nature. Common law jurisdictions, which do not know private foundations, may treat them as pass-through vehicles. Should they also be treated as transparent in their jurisdictions of incorporation, tax liabilities may arise at the founder's or beneficiaries' level, even in the absence of a present entitlement to income. To the extent that private foundations are characterized as 'tax subjects' and are actually liable to some form of income tax in their jurisdiction of incorporation, they have access to double tax conventions and compliant cross-border tax planning arrangements. This article wants to recognize some comparative features in the characterization of private foundations for income tax purposes
Citation source
In: Trusts & trustees. - Oxford. - Vol. 18 (2012),
http://library.link/vocab/creatorName
Panico, P
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • private foundation
  • entity classification
  • OECD Model
Label
Beyond 'legal personality': private foundations as 'tax subjects'
Instantiates
Publication
Label
Beyond 'legal personality': private foundations as 'tax subjects'
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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