This paper suggests a relatively simple analytical framework for taxing all financial arrangements. The debt/equity distinction is determined by the contingency principle. The accruals/realisation distinction is determined separately by the volatility principle. The capital/revenue character distinction is effectively removed directly or by a character hedging regime. Hybrids, synthetics, hedging arrangements and other portfolios are tax-assessed on an aggregate, rather than a bifurcated, basis. The framework could be applied to both classical and dividend-imputation-based business tax systems.
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Article provided by Institute for Fiscal Studies in its journal Fiscal Studies.
Volume (Year): 27 (2006) Issue (Month): 2 (June) Pages: 127-155 Download reference. The following formats are available: HTML
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