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Comparative taxation is a fascinating and frustrating subject. It is fascinating because, through the lens of tax law, one can observe how countries with very different historical and cultural traditions have grappled with similar problems and have reached solutions that have both common and disparate elements. For example, countries that start off with a schedular system for taxing different categories of income end up with near global coverage (e.g., through a "miscellaneous" schedule), and countries that adopt a global system introduce schedular elements (such as the U.S. treatment of capital gains and losses). Another example is the convergence between countries that start off with worldwide taxing jurisdiction and countries that begin with an exemption system: they both tend to tax passive income earned abroad while exempting foreignsource active income. But at the level of detail, each country's approach remains influenced by the assumptions under which it began.


Reprinted with the permission of Tax Analysts.

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