2 - The Grantor

Summary

"Chapter 2 begins by outlining the historical origins of grantor taxation in the United States and the United Kingdom and proceeds to a consideration of general/domestic grantor attribution and taxation rules in those countries and a somewhat different rule in Australia, modifications that apply in inbound or conduit situations, and the application of grantor attribution and taxation in outbound situations. Specific outbound grantor regimes are also considered here, and are contrasted with the New Zealand settlor regime. The chapter concludes by summarising the structural similarities and differences between the various rules and their international settings."