Ce travail de thèse a pour objectif d’étudier l’impact de l’introduction de la taxation des héritages sur la croissance et l’offre de travail, en considérant la diversité des transferts familiaux intergénérationnels. En effet, la transmission familiale peut être éducative, culturelle, patrimoniale, ou encore perçue comme un transfert en temps. Toutes ces formes de solidarités familiales génèrent des externalités, qui impactent différemment la croissance et l’offre de travail, ce qui peut affecter l’efficacité des politiques fiscales. Ainsi, l’impôt successoral réduit l’incitation à épargner mais peut accroître l’investissement éducatif ou les transferts en temps, ce qui peut affecter positivement la productivité des ménages et l’offre de travail. Nous développons ici des modèles théoriques à générations imbriquées avec altruisme envers les descendants. La thèse est composée de trois chapitres. Le premier chapitre permet d'étudier l’impact de la non-disponibilité de la dette publique sur la politique de redistribution intergénérationnelle mise en place par le gouvernement, en utilisant uniquement l'impôt sur les revenus du travail et l'impôt successoral. Il permet aussi d’analyser son effet sur la croissance économique et les transferts familiaux intergénérationnels, consistant en des legs et des dépenses d’éducation, en mettant en évidence le rôle central de la taxation de l’héritage. Le second chapitre propose un modèle avec legs et transferts de temps descendants, dont l’objectif est de montrer les différences entre la taxation de l’héritage et la taxation du capital de cycle de vie, sur le comportement des ménages. Nous montrons que l’utilisation de la taxation de l’héritage à la place de celle du capital peut être une reforme Pareto-améliorante, en fonction de l’effet de la réforme sur l’offre de travail. Enfin, le troisième chapitre s’intéresse aussi à la comparaison entre taxation du capital et taxation de l’héritage, dans un modèle où les dynasties sont différentes en termes de productivité et de niveau d'altruisme. Ce chapitre démontre qu’appliquer l'impôt successoral à la place de celui du capital, peut améliorer à long terme, le bien-être des moins altruistes et, dans certains cas, peut être Pareto-améliorante, si les ressources disponibles pour les plus altruistes augmentent avec la réforme. / This thesis analyzes the impact of inheritance taxation on growth and labor supply, considering the diversity of intergenerational family transfers, such that bequests, parent's education spendings or time transfers. These forms of family solidarity generate externalities, which impact growth and labor supply, and affect the effectiveness of tax policies. Concerning inheritance tax which reduces the incentive to save, it can also increase educational investment or time transfers, which can positively affect household productivity and labor supply. For this purpose, we use overlapping generations models with altruism towards offspring. The thesis is divided into three chapters. The first chapter studies the impact of public debt on intergenerational transfers and on human capital growth, using a simple tax structure with labor and bequest taxes. In this model, parents augment their children's income through education and bequest. When public debt is not available, we show that the long run growth is higher thanks to an increase of the gap between the two taxes, which underlines the role of inheritance taxation. The second chapter proposes a model with rational altruism textit{`a la} Barro, where time transfers and bequests are available to parents. We analyze a shift from capital income tax towards inheritance tax, leaving constant the capital labor ratio. We show that this reform may increase welfare of all generations. Welfare improvement mainly depends on the effect of the reform on the labor supply. This tax reform is also implemented in the third chapter where we consider that dynasties differ in productivity and altruism. We show that the tax reform increases the welfare of less altruistic dynasties but decreases welfare of the most altruistic one. Extending the model with time transfers and elastic labor supply, we identify situations where the tax reform is Pareto improving.

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The 1976 Tax Reform Act made many changes in the taxation of estate and gift transfers. Previously gifts and estates were taxed separately and the gift tax rate was 75 percent of the estate tax rate; and there was a $30,000 exemption for gifts and a $60,000 exemption for estate transfers. Under the new law the exemptions were repealed and replaced with a unified credit against the tax; and the tax on estate and gift transfers was combined into one increasing rate schedule. Under the prior law, deathbed gifts were advantageous because the gift tax paid on the transfer was excluded from the taxable estate but was allowed as a credit against the estate tax since gifts within three years of the date of death were included in the gross estate unless the estate could demonstrate that the gifts were not made in contemplation of death. Under the new law, gift taxes paid on transfers which occur within three years of the date of death are included in the taxable estate.

This thesis examines the case for a wealth transfer tax in Thailand, against the background, inter alia, of the failure of Thailand’s defunct tax law on estate and inheritance (the Estate and Inheritance Tax Act, 1933). Thailand has a significant problem with income and wealth distribution, with an increasing gulf between the rich and the poor—a root cause of the nation’s ongoing political conflicts. Such substantial economic inequality is partly caused by imbalances and inequalities in the Thai taxation system, and it will be argued that the tax system requires restructuring through the introduction of the wealth transfer tax. This would be a significant tax policy initiative that may assist in tackling a root cause of Thailand’s political and economic crises. In addressing the above issues, this thesis examines aspects of the US federal estate and gift taxes and the UK inheritance tax systems. Comparisons between the criteria, rules and concepts in the US and UK systems reveal that Thailand should not simply import wholesale the approach of either country. Both systems have commendable features that may, when combined, help address the causes of the failure of the Thai Estate and Inheritance Tax Act of 1933. It will be argued that a wealth transfer tax should be introduced in Thailand, in the form of a transferor-based system, which incorporates selected criteria, rules, and concepts arising from both the US and UK jurisdictions. In adopting the proposed reform, it is essential to consider Thailand’s political, economic, social and legal contexts, including Thailand’s current legislation relating to wealth transfers, as such laws will inform and partly shape the drafting of a prospective wealth transfer tax in Thailand.

The diploma thesis is focused on property taxes in the Czech Republic and Ireland. The first part is aimed at tax theory and history of the property taxes. The next part describes current tax legislation for property taxes in both states. The main aim of this work is to compare the property taxes in the Czech Republic and Ireland and formulate the conclusion with particular property taxes applied in the Czech Republic. This problem is treated in the last chapter.

Death and taxes are unavoidable. In terms of the current legislation both estate duty and capital gains tax (hereinafter referred to as 'CGT') are levied upon death. The South African National Treasury is reconsidering taxes on death as estate duty contributes minuscule revenue, and its administration is cumbersome. Worldwide taxation is based on either source or residence. Because of the R3 500 000 exemption from estate duty, only wealthy individuals are generally subject to estate duty. Wealthy individuals make use of the annual R4 000 000 foreign investment capital allowance by owning offshore property. The aim of this study is to document how death taxes are currently levied on an estate which holds offshore property, given the perception that foreign property is exempt from death duties, and also to consider the impact on taxes payable on offshore property at death if estate duty were to be abolished. These objectives cannot be achieved without a thorough understanding of the development and future of estate duty, the impact of CGT on death, how selected foreign countries levy taxes upon death, and how residents of South Africa are taxed on property situated within foreign countries. When CGT was introduced in 2001 the estate duty rate was reduced and it is likely that, if estate duty is repealed, the rate of CGT will be increased. In South Africa, residents are taxed on worldwide income and capital gains. The international perspective is that the foreign country has the sovereignty to levy taxes on a person who owns property situated within its boundaries. An estate which holds offshore property may also be subject to estate duty in terms of the tax law of that country which results in double taxation in the hands of the deceased estate. South Africa has concluded international agreements with a number of foreign countries through double tax agreements and estate tax treaties to prevent double taxation. In terms of the Estate Duty Act, and in some of the treaties, a rebate is allowed in respect of foreign estate taxes paid. However, if estate duty is abolished, the deceased estate may be liable for estate tax in the foreign country where the assets are situated and the deceased estate may not qualify for any rebate in South Africa in respect of foreign taxes paid. Hence, the abolition may have detrimental consequences on the liquidity requirements, and on the heirs, in cases where offshore property is involved. It is vital that proper estate and tax planning advice is given before a resident acquires offshore property as the tax implications may be enormous. The current impact of estate duty and CGT on a resident who owns offshore assets is that the said taxes will be levied either here in South Africa or in the foreign country. The effect of capital transfer tax on a resident with an offshore asset can never be underestimated. / Thesis (M.Com. (Tax))--North-West University, Potchefstroom Campus, 2011.

Death and taxes are unavoidable. In terms of the current legislation both estate duty and capital gains tax (hereinafter referred to as 'CGT') are levied upon death. The South African National Treasury is reconsidering taxes on death as estate duty contributes minuscule revenue, and its administration is cumbersome. Worldwide taxation is based on either source or residence. Because of the R3 500 000 exemption from estate duty, only wealthy individuals are generally subject to estate duty. Wealthy individuals make use of the annual R4 000 000 foreign investment capital allowance by owning offshore property. The aim of this study is to document how death taxes are currently levied on an estate which holds offshore property, given the perception that foreign property is exempt from death duties, and also to consider the impact on taxes payable on offshore property at death if estate duty were to be abolished. These objectives cannot be achieved without a thorough understanding of the development and future of estate duty, the impact of CGT on death, how selected foreign countries levy taxes upon death, and how residents of South Africa are taxed on property situated within foreign countries. When CGT was introduced in 2001 the estate duty rate was reduced and it is likely that, if estate duty is repealed, the rate of CGT will be increased. In South Africa, residents are taxed on worldwide income and capital gains. The international perspective is that the foreign country has the sovereignty to levy taxes on a person who owns property situated within its boundaries. An estate which holds offshore property may also be subject to estate duty in terms of the tax law of that country which results in double taxation in the hands of the deceased estate. South Africa has concluded international agreements with a number of foreign countries through double tax agreements and estate tax treaties to prevent double taxation. In terms of the Estate Duty Act, and in some of the treaties, a rebate is allowed in respect of foreign estate taxes paid. However, if estate duty is abolished, the deceased estate may be liable for estate tax in the foreign country where the assets are situated and the deceased estate may not qualify for any rebate in South Africa in respect of foreign taxes paid. Hence, the abolition may have detrimental consequences on the liquidity requirements, and on the heirs, in cases where offshore property is involved. It is vital that proper estate and tax planning advice is given before a resident acquires offshore property as the tax implications may be enormous. The current impact of estate duty and CGT on a resident who owns offshore assets is that the said taxes will be levied either here in South Africa or in the foreign country. The effect of capital transfer tax on a resident with an offshore asset can never be underestimated. / Thesis (M.Com. (Tax))--North-West University, Potchefstroom Campus, 2011.

This diploma thesis is focused on a critical comparison of the tax burden on real estate in the Czech Republic and in selected countries of the European Union. At first, comparison will be implemented on the general level, after that a practical calculation for the most popular type of housing will be realized. This thesis provides a comprehensive view of the tax on real estate and business transfer. A comparison of taxes related with real estate in the countries of the European Union will be used for a prediction of the tax burden on real estate in the Czech Republic for the following years.

This diploma thesis focuses on the analysis of the effectiveness of transfer taxes in the period 2006 to 2010 in the Czech Republic. The first part of this thesis describes the historical development and the basic characteristics of transfer taxes in the Czech Republic and analyzes in details the current legislation. The second part deals with the analysis of the effectiveness of transfer taxes, i.e. measurement of the administrative costs of taxation and their subsequent comparison with revenues. The measurement of the administrative costs is used by the method called WTE staff. On the base of the measurement is done the conclusion about the administrative costs of taxation and about efficiency of transfer taxes in the tax system of the Czech Republic. The third part discusses on plans for future development in this area of transfer taxes in the Czech Republic.

Diploma thesis is focused on the comparison of the tax burden on residential property owner in the Czech Republic and in selected European countries. The content of this thesis is a comprehensive review of taxes relating to real estate in our country, their detailed analysis and subsequent comparison with the situation of selected countries. The possible future development of property taxation in the Czech Republic is predicted in conclusion.