IFA Cahiers / Cahiers de Droit Fiscal International Volume LXXXVIIIa - 2003 ; Trends in company/shareholder taxation: single or double taxation?

The panel will examine the on-going efforts by governments to keep their company shareholder tax systems competitive with other countries and (where relevant) compliant with international and EC law. In particular the demise of imputation in several countries and its replacement with shareholder relief systems of various kinds will be discussed, as well as the recent US proposal to abolish its long standing classical system. In addition to the treatment of dividends, the Panel will consider the extent to which the treatment of capital gains on shares in an international setting is now being viewed as part of the company shareholder tax issue.