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36 Austl. Tax F. 187 (2021)
Parameters for Applying the Two Methods of Taxation: The Historical Justifications

handle is hein.journals/austraxrum36 and id is 192 raw text is: Parameters for applying the two methods of taxation: the historical justifications Alex C Evans* Abstract The design of the domestic settings for taxing income derived through resident vehicles is a perennial topic of debate. Although this debate in Australia has most recently centred around the corporation, over the past twenty-five years, it has also recurred in relation to the design of the rules for taxing the trust, which is the primary alternative vehicle to the corporation. One question that has been absent from, but would have aided, these debates is - in what circumstances is it appropriate to apply entity taxation in the domestic context? The answer to this, by extension, also answers the corollary - in what circumstances is it appropriate to apply flow-through taxation? This article fills this gap by critically analysing the reasons that have historically been used to justify imposing an entity tax and the theories that underpin them (where relevant). The article uses comparative analysis, drawing on literature from the United Kingdom (UK) and the United States of America (US). The body of English literature is most valuable for outlining the history that led to the paradigm of applying entity taxation to companies and flow-through taxation to partnerships. The American literature is deeper and richer on both the theoretical and philosophical dimensions. Senior Lecturer, School of Accounting, Auditing & Tax, UNSW Business School, UNSW Sydney. This article was accepted for publication on 5 March 2021. I 87

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