Mark Brabazon

The University of Sydney Law School

New Law Building, F10

The University of Sydney

Sydney, NSW 2006

Australia

SCHOLARLY PAPERS

12

DOWNLOADS

753

SSRN CITATIONS

1

CROSSREF CITATIONS

0

Scholarly Papers (12)

1.

BEPS Action 2: Trusts as Hybrid Entities

British Tax Review, No. 2, 2018, Sydney Law School Research Paper No. 18/42
Number of pages: 34 Posted: 22 Jun 2018
Mark Brabazon
The University of Sydney Law School
Downloads 197 (184,920)

Abstract:

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Base erosion and profit shifting (BEPS), Hybrid mismatch arrangements, OECD, Trusts, International taxation, Fiscally transparent entities

2.

Australian International Taxation of Attributed Trust Gains

Australian Tax Review, Vol. 44, No. 3, pp. 141-166, 2015, Sydney Law School Research Paper No. 15/05
Number of pages: 49 Posted: 04 Feb 2015 Last Revised: 17 Aug 2015
Mark Brabazon
The University of Sydney Law School
Downloads 168 (212,602)

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Australian international taxation, international trust taxation, capital gains tax (CGT), fiscal attribution, conduit principle, streaming, source of capital gains, statutory interpretation, tax history, tax complexity

3.

The Hatter's Watch: Tax Benefit in Part IVA

Australian Tax Review, Vol. 43, No. 3, pp. 150-161, 2014, Sydney Law School Research Paper No. 14/84
Number of pages: 22 Posted: 06 Sep 2014 Last Revised: 30 Mar 2015
Mark Brabazon
The University of Sydney Law School
Downloads 95 (325,964)

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Tax avoidance, General anti-avoidance rules, Statutory interpretation, Tax benefit

4.

Trust Residence, Grantor Taxation and the Settlor Regime in New Zealand

New Zealand Journal of Taxation Law and Policy, Vol. 22, No. 4, pp. 346-373, 2016, Sydney Law School Research Paper No. 16/55
Number of pages: 38 Posted: 18 Jun 2016 Last Revised: 31 Jan 2017
Mark Brabazon
The University of Sydney Law School
Downloads 81 (359,513)

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International trust taxation, trust residence, fiscal residence, New Zealand, settlor regime, grantor taxation, tax havens, tax avoidance, Panama Papers

5.

After the Flood: Transparent and Hybrid Entities in Australian Treaties after the MLI

eJournal of Tax Research Vol 17 No 1, 2019, Sydney Law School Research Paper No. 19/61
Number of pages: 35 Posted: 03 Oct 2019
Mark Brabazon
The University of Sydney Law School
Downloads 66 (402,783)
Citation 1

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international taxation, tax treaties, fiscally transparent entities, hybrid entities, OECD/G20 base erosion and profit shifting (BEPS) project, Multilateral Instrument (MLI), OECD Partnership Report, trusts, partnerships

6.

Ariadne in the South: New Zealand International Taxation of Passive Trust Income

New Zealand Journal of Taxation Law and Policy, 2017, Forthcoming, Sydney Law School Research Paper No. 16/101
Number of pages: 38 Posted: 06 Dec 2016
Mark Brabazon
The University of Sydney Law School
Downloads 44 (484,174)

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International trust taxation, dividend interest and royalty withholding, trust residence, attribution of income, DIR / passive income, approved issuer levy (AIL), foreign investor tax credit, New Zealand

7.

Residency and Trusts

Number of pages: 35 Posted: 18 Nov 2019
Mark Brabazon
The University of Sydney Law School
Downloads 34 (530,898)

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International trust taxation (Australia), Fiscal residence, Capital gains taxation, Tax history

8.

Tolerating Deferral: Australia's Proposed Foreign Accumulation Fund Rules

(2010) 39 Aust Tax Review 205
Number of pages: 41 Posted: 30 Mar 2015
Mark Brabazon
The University of Sydney Law School
Downloads 28 (563,506)

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Australian international taxation, accumulation funds, foreign source income (FSI), tax deferral, anti-deferral, tax avoidance

9.

Holding Proteus: Emerging Treaty Practice on Hybrid and Fiscally Transparent Entities

British Tax Review, No. 5, 2020
Number of pages: 25 Posted: 11 Feb 2021
Mark Brabazon
The University of Sydney Law School
Downloads 22 (601,753)

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OECD Model tax treaty, Fiscally transparent entities, International taxation, Tax treaty history, Legal history, Hybrid entities, Partnerships

10.

Barristers’ Work as a GST-Free Export

(2010) Aust Law Jnl 433, (2010) 10 Aust GST Jnl 37
Number of pages: 11 Posted: 31 Mar 2015
Mark Brabazon
The University of Sydney Law School
Downloads 18 (628,830)

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Australian international taxation, consumption tax, VAT, goods and services tax, cross-border supply of services, barristers, indirect taxation

11.

Partial Residence Clauses in US Treaty Practice

74 (8) Bulletin for International Taxation 497-510, 2020
Posted: 16 Oct 2020
Mark Brabazon
The University of Sydney Law School

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Tax Treaties, United States, Fiscally transparent entities, Partnerships, Trusts, International taxation, Legal history

12.

Are We There Yet? International Implementation of Hybrid Mismatch Rules

Sydney Law School Research Paper No. #19/46
Posted: 24 Jul 2019
Mark Brabazon
The University of Sydney Law School

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international taxation, hybrid mismatch rules, OECD/G20 base erosion and profit shifting (BEPS) project, EU Anti-Tax Avoidance Directive (ATAD), tax avoidance, Australia, New Zealand, United Kingdom, United States