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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:

Ranjana GUPTA
Ranjana is a Senior Lecturer,Taxation, Law School, Faculty of Business and Law, Auckland University of Technology.
Current at 01 March 2015
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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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Author Photo - Brett Freudenberg CTA
Dr Brett Freudenberg CTA
Brett works at the Department of Accounting, Finance and Economics, Griffith Business School, Griffith University. In addition to his taxation teaching, Brett was awarded a PhD for his research into tax transparent companies in the US, the UK and New Zealand, and how Australian closely held businesses may benefit from their introduction. In 2009 Brett was invited to present his PhD research findings to the Australian Treasury as part of the Henry Tax Review. In 2006 Brett received a Fulbright Award, which saw him conducting research at the University of Illinois to analyse the proliferation of new business forms in the United States and their potential application for Australian businesses. Brett has published refereed articles in leading Australian and international tax journals. In addition to his tax expertise, Brett has received a number of teaching accolades, including in 2008 a national teaching citation from the Australian Learning & Teaching Council for his outstanding contributions to student learning. Current at 01 July 2016 Click here to expand/collapse more articles by Brett FREUDENBERG.

Binh is an Associate Professor, School of Taxation and Business Law, UNSW and Senior Fellow, Taxation Law and Policy Research Institute, Monash University.
Current at 01 May 2014
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