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Concepts of residence and source into the 21st century seminar paper

Published on 14 Jun 96 by VICTORIAN DIVISION, THE TAX INSTITUTE

The concepts of residence and source are fundamental to the design of taxation structures. Theoretically a country can levy taxes on any person it chooses with respect to any economic activity or asset and wherever situated. But the pragmatic problems of enforcement with respect to subjects or objects of taxation beyond the borders of a country have led to the establishment of two basic principles which determine fiscal structures: the source principle and the residence principle.

Author profile

Hon Ian Vitaly Gzell AM QC QC FTI-Life
The Hon. Justice Ian Gzell FTIA (Life) was admitted to the Queensland Bar in 1965 and was appointed Queen’s Counsel in Queensland in 1977. He was appointed to the Equity Division of the Supreme Court of New South Wales in 2002 where, apart from his other duties, he is the Revenue List Judge. He was admitted as a Barrister in every state and territory in Australia and in New Zealand and Papua New Guinea, with admissions for multiple single causes in Singapore, Fiji and the Solomon Islands. At the Bar, Ian specialised in revenue law with particular emphasis on international taxation. He was President of The Taxation Institute from 1985-1986, President of the Commercial Law Association of Australia from 1994-1996 and has been Vice President, Western Pacific, of The International Academy of Estate and Trust Law since 2005 and Chairman of the Society of Trust and Estate Practitioners, Australia, Sydney Branch since 2007. He has had numerous articles published and is in constant demand as a speaker. - Current at 11 July 2008
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This was presented at International Tax into the 21st Century .

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Individual sessions

Cross border leasing - asymmetrical taxation treatment

Author(s):  Oliver YATES

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Concepts of Residence & Source into the 21st Century

Author(s):  The Hon. Justice Ian GZELL

Materials from this session:

Outbound investment - listed countries

Author(s):  Tony CLEMENS

Materials from this session:

Outbound investments

Author(s):  Peter DIMECH,  David SCOTT

Materials from this session:

Foreign tax credits - past, present and future

Author(s):  Richard SHADDICK

Materials from this session:

Inbound investments

Author(s):  Grant MILLARD

Materials from this session:

Developments in international tax law

Author(s):  Richard J VANN

Materials from this session:

Dealing with dividend streams

Author(s):  Tony PANE

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ATO's approach to international tax into the future

Author(s):  Jim KILLALY

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