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A comparative analysis of tax advisers’ perception of small business tax law complexity: United States, Australia and New Zealand


There is no doubt that the tax laws of many countries are complex and difficult to comply with administratively. In particular, Australia, New Zealand and the United States have tax systems that are generally recognized as complex especially for small businesses. They also have the distinction of having had a significant portion of their tax policy literature address the issue of complexity and its impact. What has been given scant recognition is the ability of different tax systems to learn from the successes and failures of each other.

This article will try to bridge that gap by comparing tax advisers’ perceptions of tax law complexities in these three jurisdictions that impact a crucial segment of the economy, small business.

Author profiles

Dr Brett Freudenberg CTA
Brett is a Professor – Taxation at Griffith University (Australia). Brett is known for his research expertise in the tax law and policy issues facing private enterprises, as evidenced by his Fulbright Scholarship (2006) and over 70 refereed publications in leading Australian and international journals. In 2020, he was awarded the national ATTA-Hill medal in recognition of outstanding contribution to Australasian tax policy and tax teaching. Professor Freudenberg’s research has analysed whether Australia should introduce a tax flow-through company, the tax treatment of discretionary trusts and the motivation for choice of business structure. His research has also considered the tax issues confronting private enterprises, reforms for enterprises in the arts sector, as well as to facilitate Islamic finance. Professor Freudenberg’s research has informed government policy as he was invited to present his PhD research findings to the Australian Treasury as part of the Henry Tax Review. Also his PhD was awarded the CCH-ATTA Doctoral Prize which saw it published as a book in 2011: Tax Flow-Through Companies. Brett is passionate about education being a transformative process, and his effectiveness as a teacher has been recognised through five national awards (including the award of two Australian Learning and Teaching Council citations: 2008 & 2011). - Current at 17 April 2020
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Ranjana Gupta
Ranjana is a Senior Lecturer,Taxation, Accounting Department, Faculty of Business, Economics and Law, Auckland University of Technology. - Current at 17 April 2020
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Stewart is a professor in the College of Business, San Jose State University and a Visiting Fellow in the Taxation Law and Policy Research Institute, Deakin University.
Current at 20 July 2004
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Binh Tran-Nam
Binh is a Professor, School of Taxation & Business Law, UNSW Australia and RMIT Asia Graduate Centre, RMIT University Vietnam, and International Fellow, Tax Administration Research Centre, Exeter University-Institute for Fiscal Studies. - Current at 03 November 2016
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