Comparative Income Taxation: A Structural Analysis. 2nd Edition

3 Pages Posted: 15 Nov 2004

See all articles by Hugh J. Ault

Hugh J. Ault

Boston College Law School

Brian J. Arnold

Goodmans LLP Toronto


This work presents a comparative analysis of some of the structural and design issues which are involved in mature income tax systems. Countries selected for the study are Australia, Canada, France, Germany, Japan, The Netherlands, Sweden, the United Kingdom and the United States. Each of the systems has evolved its own particular set of approaches and principles, outlined in Part One. Ensuing Parts deal with Basic Income Taxation, Taxation of Business Organizations and International Taxation. There is much to learn in the tax field from a comparative analysis of common problems. One need not believe in the existence of a Platonic Tax Form to find useful insights in the experience of others.

Keywords: income tax, business organizations, international taxation, mature tax systems

Suggested Citation

Ault, Hugh J. and Arnold, Brian J., Comparative Income Taxation: A Structural Analysis. 2nd Edition. Boston College Legal Studies Paper No. 50, Available at SSRN:

Hugh J. Ault (Contact Author)

Boston College Law School ( email )

885 Centre Street
Newton, MA 02459-1163
United States

Brian J. Arnold

Goodmans LLP Toronto ( email )

250 Yonge Street
Suite 2400, Box 24
Toronto, Ontario M5B 2M6
(416) 597-2015 (Phone)

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