THE TAXATION OF IMPUTED INCOME AND THE RULE IN SHARKEY V. WERNHER

Authors

  • A F SHEPPARD

Abstract

Based on economists’ current dissatisfaction with the narrow definition of taxable income and a number of other assumptions, this article examines the supposition that the tax base excludes imputed income. After explaining the definition of imputed income and the arguments for and against including it in the definition of taxable income, it examines the following categories of imputed income: imputed rent and interest, self-supply of goods, self-supply of services, housewives’ services and mutual trading. The author considers the extent to which Parliament and the courts have attained the theoretical ideal of bringing imputed income within the concept of taxable income and qualifies the assumption that the tax base excludes it, suggesting a consumption tax may be the only answer

Keywords:

Tax Law

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Published

1973-12-01

Issue

Section

Legal Commentary