Selected aspects of capital gains taxation in Australia, New Zealand, the United Kingdom and the United States

The authors of this paper compare various structural aspects of the capital gains tax systems in Canada and four selected countries: (i) Australia, (ii) New Zealand, (iii) the United Kingdom, and (iv) the United States. The principal focus is on the lifetime capital gains exemption in Canada and the availability of comparable exemptions, preferences and reliefs for capital gains in these other countries. Despite the common legal and taxation traditions in the selected countries, the review reveals a surprising number of differences in the approaches to the taxation of capital gains. These differences are found in all of the usual structural aspects of a capital gains tax system. One of the more striking features of the systems in the four other countries is the lack of any general exemption comparable to the lifetime gains exemption in Canada.