信託財産に係る課税について英語でまとめました。
An overview of classification of trusts and their taxation is as shown in the table below.
|
Taxpayer |
Timing of tax |
Examples |
Tax treatment |
Other |
Type 1 (Juekisha
tou kazei shintaku) |
Beneficiary
|
When
profit accrues to the trust |
General trusts |
The
beneficiary is deemed to own assets and liabilities of, and profits and
expenses attributable to, the trust. |
General
taxation of trusts (i.e., pass-through) |
Type 2 (Shuudan
toushi shintaku tou) |
Beneficiary
|
When
profit is distributed to beneficiary |
Trusts
for collective investment scheme |
The
beneficiary is deemed to own assets and liabilities of, and profits and
expenses attributable to, the trust. |
The
trustee must be a corporation |
Type 3 (Houjin
kazei shintaku) |
Trustee |
When
profit accrues to the trust |
Trusts for
securitization of real estate or certain other assets |
The
trustee is taxed on the following separately: A. Assets and liabilities of, and profits and
expenses attributable to, the trust B. Its other assets and liabilities, and
profits and expenses |
The trustee,
whether corporation or individual, is subject to corporate income tax |
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