DOUBLE taxation is one of many subjects which have assumed much increased importance as a result of the war. Nor is the increased importance due solely to higher rates of taxation, though the imposition of taxes running up to more than 50 percent has created situations in which double taxation of income amounts to practical expropriation. Another serious factor is the change in the fiscal situation of the leading countries which the war has brought about. Countries which before the war were in position to supply their own requirements of capital or even had a surplus for investment abroad, have become borrowers; other countries have found themselves not only in a position to invest abroad but almost compelled to do so. Our own country could hardly maintain its policies of restriction of imports through high tariffs, exportation of surplus food products, collection of foreign government debts and the building up of a merchant marine, without making foreign investments to balance the international account.
Again, lack of confidence in domestic finance and depreciation of currencies have created a demand for foreign investments even in countries whose capital resources are inadequate for their own requirements, and in the most stable European countries anxious investors having seen the disastrous consequences of war on the strongest of states, have felt that it was unwise to put all their eggs in a single basket, and have invested part of their capital abroad.
The setting up as separate nations of what were formerly parts of a single kingdom, which remain more or less economically interdependent, as in the case of the succession states of Austria, is still another of the many contributing influences as a result of which the subject has assumed very real and general significance.
The problem arises mainly in relation to income and inheritance taxes. In its international aspects double taxation of income is by far the most important phase of the question, but in our own country double taxation of inheritances by the
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