Practical Guide to the Taxation of Financial Instruments and Transations PDF Download
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Author: Michael J. Feder Publisher: ISBN: 9780808029014 Category : Languages : en Pages : 300
Book Description
Virtually every large U.S. or foreign-based multinational company has a treasury department that is responsible for raising capital, managing risk, and handling investment activities. This proposed work is designed and written to help in-house and external tax advisors understand the tax law that applies to common treasury functions including the taxation of financial products and transactions. The tax law in the financial instruments and transactions area changes frequently. In addition, with the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, there is a possibility that extremely significant changes may be made to the manner in which common risk management and investment transactions are taxed.
Author: Michael J. Feder Publisher: ISBN: 9780808029014 Category : Languages : en Pages : 300
Book Description
Virtually every large U.S. or foreign-based multinational company has a treasury department that is responsible for raising capital, managing risk, and handling investment activities. This proposed work is designed and written to help in-house and external tax advisors understand the tax law that applies to common treasury functions including the taxation of financial products and transactions. The tax law in the financial instruments and transactions area changes frequently. In addition, with the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, there is a possibility that extremely significant changes may be made to the manner in which common risk management and investment transactions are taxed.
Author: Michael J. Feder Publisher: CCH Incorporated ISBN: 9780808029052 Category : Commodity exchange Languages : en Pages : 0
Book Description
Virtually every large U.S. or foreign-based multinational company has a treasury department that is responsible for raising capital, managing risk, and handling investment activities. This work is designed and written to help in-house and external tax advisors understand the tax law that applies to common treasury functions including the taxation of financial products and transactions. The tax law in the financial instruments and transactions area changes frequently. In addition, with the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, there is a possibility that extremely significant changes may be made to the manner in which common risk management and investment transactions are taxed.
Author: Robert T. Cole Publisher: Aspen Publishers ISBN: Category : Business & Economics Languages : en Pages : 1302
Book Description
Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.
Author: Michael Lang Publisher: Kluwer Law International B.V. ISBN: 904119021X Category : Law Languages : en Pages : 500
Book Description
Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.
Author: Raffaele Petruzzi Publisher: Kluwer Law International B.V. ISBN: 9403540338 Category : Law Languages : en Pages : 261
Book Description
In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties. Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions: loans; financial guarantees; cash pooling; hybrid financing; factoring; captive insurance; and asset management. Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law. Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.
Author: David Southern Publisher: ISBN: 9780754512196 Category : Languages : en Pages :
Book Description
This title focuses on the practical implications of the provisions on corporate debt, financial instruments and foreign exchange gains and losses. It covers the interaction between the taxes, the accounting framework, corporate transactions and planning issues. It is a comprehensive and practical guide to the corporate and government debt rules, to the tax and accounting treatment of all instruments used in providing corporate finance, and the treatment of foreign exchange gains and losses arising from such financial transactions. Worked examples throughout illustrate complex points, and it is fully cross-referenced to the legislation and Inland Revenue pronouncements. Changes in practice and legislation up to and including the Finance Act 2001 are included.
Author: Santosh Maller Publisher: Bloomsbury Publishing ISBN: 9390176395 Category : Law Languages : en Pages : 800
Book Description
About the book Accounting for financial instruments under Ind AS is generally complex. In India, we do not have much of a history of a comprehensive and robust accounting framework for financial instruments. Historically, accounting for financial instruments is primarily based on form rather than the contractual terms of instruments. Focus on accounting for financial instruments started only since 2007. Owing to global financial crisis which raised issues regarding accounting treatment of financial instruments, various accounting standards setting bodies examined the robustness of accounting for financial instruments. Further, Ind AS transition resulted in high-quality, principles-based, globally comparable financial reporting of large Indian companies. Accounting for financial instruments under Ind AS is quite robust and comprehensive. Towards this end, this book attempts to provide insights and in-depth analysis on interpretative issues and complex principles in the Ind ASs dealing with financial instruments. The requirements of Ind AS 32, Financial instruments: Presentation, Ind AS 109, Financial instruments, and Ind AS 107 Financial instruments: Disclosures are extensively dealt with. There are separate chapters addressing: Scope of the requirements. Debt/equity classification. Classification. Recognition and Derecognition. Subsequent measurement. Fair values and impairment. Hedge accounting. Presentation and Disclosures. Implications on key provisions of Companies Act, 2013. ICAI's Guidance Note on Accounting for Derivative Contracts. This book is intended to help the companies to identify Ind AS requirements that are relevant to them and evaluate various aspects of financial instruments accounting. The book would be an immensely useful referencer for professionals, practitioners and corporates. Key features - To simplify the reading experience, the chapters include a brief, easy to understand, summary of the relevant topic, followed by Frequently Asked Questions (FAQs) on the chapter. - Covers examples-based illustrations of complex topics. - Covers case studies on hedge accounting with journal entries, guidance for hedge documentation and effectiveness testing. - Includes real life extracts of disclosures of financial instruments. - Covers the amendment related to LIBOR and other interbank offered rates ('IBORs') issued by the Ministry of Corporate Affairs vide Companies (Indian Accounting Standards) Amendment Rules, 2020 on 24 July, 2020. - Covers key implications of Ind AS under Companies Act, 2013.About the book
Author: Dominic Daher Publisher: Cch Incorporated ISBN: 9780808027898 Category : Business & Economics Languages : en Pages : 357
Book Description
Practical Guide to C Corporations offer practitioners current and practical explanation and analysis on corporations, giving them the guidance needed to manage the C Corporation election, compliance, tax planning, and life cycle needs. In addition to thorough coverage of how the tax laws impact C corporations, the Practical Guide details corporate formation, distributions, redemptions, liquidations, reorganizaitons and issues related to corporate tax practice and procedure. Practical Guide to C Corporations provides business entity practitioners with complete coverage of C corporation taxation issues.
Author: Michael J. Feder
Author: Michael J. Feder
Author: Michael J. Feder
Author: Arlene Mary Hibschweiler
Author: Robert T. Cole
Author: Michael Lang
Author: Raffaele Petruzzi
Author: David Southern
Author: Santosh Maller
Author: Dominic Daher
Author: John I. Tiner