"Chapter 5 addresses the taxation of distributions as income from a trust. It first considers the broadly synoptic approaches of Australia, the United States and New Zealand, which use distribution taxation as a complementary international rule. It compares key elements of those countries’ rules with reference to scope, tracing principles, international double tax relief (an area of considerable divergence) and the treatment of tax-deferral benefits. It then considers the UK approach, its integration with domestic taxation, its modifications in inbound and outbound situations and a separate UK rule that applies to capital gains."