The Concept Of Income: A Multi Disciplinary Analysis

Abstract

Doctoral Series: Vol. 1 The Concept of Income A MultiDisciplinary Analysis CONTENTS PART I: THEORY OF INCOME CHAPTER 1: TAX FAIRNESS Introduction Wellbeing Optimal Tax Theory Fairness Horizontal Equity Ability to Pay Global and Schedular Income Tax Systems Summary CHAPTER 2: FOUNDATION CONCEPT OF INCOME Introduction Psychic Income Goods and Services Fisher's Analysis of Total Flow of Services Posner's Nonpecuniary Benefits Subjective Measurements The Search for Objectivity Money Income Consumption Expenditure Source of Satisfactions Development of the SchanzHaigSimons Model The Schanz Contribution The Haig Contribution Reconciliation of Wealth Accrual and Psychic Based Concepts of Income Simons's Concept Rights and Expectations Hicksian Analysis Fisher's Exclusion of Savings Imputed lncome Superiority of the SchanzHaigSimons Based Foundation Concept of lncome Summary CHAPTER 3: ECONOMISTS' DEVIATIONS FROM THE FOUNDATION CONCEPT OF INCOME Introduction Preservation of Source Clear Surplus and Human Capital Maintenance Net Product Productivity Periodicity Essential Nature of Periodicity Permanence of Source Summary CHAPTER 4: ACCOUNTANTS' INCLINATION TOWARDS THE FOUNDATION CONCEPT OF INCOME Introduction Recasting Hicks's Definition of Income Periodic Measurement Transactions Approach and Realization of lncome Doctrine of Conservatism Influence of Taxation Law on Accounting lncome Foundation Concept of Income and Transactions and Realization Approaches Modified Historic Cost Holding Gains Liabilities Comprehensive lncome International Accounting Concepts United States Accounting Concepts Australian Accounting Concepts New Zealand Accounting Concepts Remaining Differences Between Foundation and Accounting Concepts of lncome Summary CHAPTER 5: DEVELOPMENT OF THE LEGAL CONCEPT OF TAXABLE INCOME Introduction Income and Other Receipts and Benefits Genesis of United Kingdom Income Tax Legislation Incomings Convertibility into Cash Periodicity Rewards of Employment or Vocation History of the Legal Distinction Between Income and Other Receipts in England Realization Trust Law Principle Transposition of Trust Law Principle to Income Tax Law Precarious Income Form, Substance, and Economic Effect Genesis of New Zealand Income Tax Legislation United States History of the Legal Treatment of lncome and Capital Eisner v. Macomber Inappropriateness of the Res Concept Incompatibility of Trust Law Principle and Tax Policy Objectives Ordinary Concepts and Usages Ectopic Income Tax Law Summary PART II: SELECTED ECONOMIC EVENTS CHAPTER 6: BUSINESS INCOME Introduction Ordinary Gains in the Course of Business Banking Companies Insurance Companies Finance Companies Investment Companies Other Types of Business Profit Making Purpose and Scheme Extraordinary Transactions in the Course of Business Australian Hire Company Cases Summary CHAPTER 7: TIMING OF INCOME RECOGNITION Introduction Myer Emporium and the Foundation Concept of Income Lease Inducement Payments Distinction Based on Choice Interpretation of Lease Agreement New Zealand Judicial View of Lease Inducement Payments New Zealand Legislation Patent Rights Film Owners Royalties Summary CHAPTER 8: ILLUSORY GAINS Introduction Inflationary Gains Bonus Share Issues Cum Dividend Shares Share Repurchases Further Consequences Myer Recognition of Value Annuities Legislative Language Summary CHAPTER 9: CAPITAL. GAINS Introduction Realized Capital Gains Capital Losses Inconsistencies in New Zealand Tax Legislation Personal Property Sales Land Sales Purpose Subjective Purpose Dominant Purpose Purpose and Intention Expected and Unexpected Gains Undertaking or Scheme Degree of Precision Debt Instruments Excepted Financial Arrangements Cash Basis Holders Summary CHAPTER 10: GIFTS AND WINDFALL GAINS Introduction Meaning of Gift and Windfall Gain Psychological Factors Cultural Considerations Koha Accounting Treatment Exclusion of Gifts and Windfall Gains from the Legal Concept of Income Gifts from Employers Question of Degree Exceptionality Criterion Different Judicial Interpretations of Fact United States Approach Koha and the Legal Concept of Income Intrafamily Payments New Zealand Tax Legislation Summary CHAPTER 11: BENEFITS OF KIND Introduction Issues of Definition Deferred Property Settlements Economic Income Accounting for Benefits in Kind United Kingdom Legal Concept Dual Benefit to Employee and Employer Valuation and Rights Judicial Reservations about the Convertibility Principle New Zealand Cases Legislative Amendments Benefits from Expenditure Saved Fringe Benefit Tax Frequent Flyer Rewards Summary CHAPTER 12: IMPUTED INCOME Introduction Meaning of Imputed Income Theoretical Considerations Owner Occupied Housing Self Performed Services Leisure Measurement Difficulties International Experience United Kingdom Australia European Jurisdictions Other Jurisdictions New Zealand Summary CHAPTER 13: CONCLUSION The Underlying Premise The Foundation Concept of Income Market Valuation Liquidity Constraining Factors Inadequacies of the Legal Concept of Income The Next Step References Bibliography Case References Statutory and Parliamentary References

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