Source Rule for Capital Gains from Stock Sales – History and Evolution

Journal
Shi, X.
International
Asia-Pacific Tax Bulletin 2013 (Volume 19), No. 1
PriceUSD 45

This article firstly explores the historical tax practices in determining the source of capital gains from share sales, and then goes on to cover the evolution of the rule in international model conventions. The author also proposes a solution to the challenges posed by the current source rule for such gains.