Author: Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 1228
Book Description
Tax Notes International
Author: Data Base Directory
Author: Publisher:
ISBN:
Category : Information storage and retrieval systems
Languages : en
Pages : 632
Book Description
Official Congressional Directory
Author: United States. CongressPublisher:
ISBN:
Category :
Languages : en
Pages : 1272
Book Description
Official Congressional Directory, 110th Congress
Author: Joint Committee on Printing United States CongressPublisher: Official Congressional Directo
ISBN: 9781598043853
Category : Biography & Autobiography
Languages : en
Pages : 1238
Book Description
Structuring Cross-Border Transactions
Author: Mindy HerzfeldPublisher: Kluwer Law International B.V.
ISBN: 9403528915
Category : Law
Languages : en
Pages : 435
Book Description
Structuring Cross-Border Transactions: U.S. Tax Considerations The U.S. international tax provisions that impact cross-border transactions are far-reaching. In recent years, the rules have become more complex, less systematic, and more difficult to make sense of. In this helpful book, a well-known author and practitioner demystifies many of the structuring questions implicated in inbound and outbound cross-border investments, acquisitions, and joint ventures, exposing traps and planning opportunities and showing how the rules really operate in specific fact patterns. All key aspects of structuring a cross-border transaction are analyzed, including: anti-deferral regimes (subpart F and global intangible low-taxed income (GILTI)); how check-the-box (CTB) regulations can maximize tax benefits and minimize tax inefficiencies; how the indirect foreign tax credit provides opportunities for tax beneficial planning; U.S. tax-free reorganization rules as they apply in the cross-border area; U.S. anti-inversion rules that affect cross-border deals; effect of anti-hybrid rules; concerns of particular classes of investors that will influence the form of a transaction; and typical points of friction between buyers and sellers in the cross-border context. Detailed examples, with financial metrics included, help guide decision making at every step and assist in the understanding of key drivers materially impacting results. Treaty considerations and implications are discussed throughout. This book fills a big gap in the tax literature by providing a guide for practitioners from any country who need to understand the U.S. tax consequences of a particular transaction. Its focus on how U.S. tax law affects the ways in which transactions are put together in the real world, and its in-depth analysis of how U.S. tax provisions interrelate and interact with foreign tax rules will prove of immeasurable value to corporate lawyers, finance professionals, and others active in cross-border mergers and acquisitions. It will become an indispensable reference tool for transactional tax practitioners.
Nominations of Michael Punke, Islam Siddiqui, and Michael Mundaca
Author: United States. Congress. Senate. Committee on FinancePublisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 184
Book Description
Comparative Law Yearbook of International Business Volume 43
Author: Christian CampbellPublisher: Kluwer Law International B.V.
ISBN: 9403535318
Category : Law
Languages : en
Pages : 195
Book Description
The Comparative Law Yearbook of International Business, published under the auspices of the Center for International Legal Studies, in this 43rd volume spans an arc of timely and challenging concerns for business law practitioners and academics alike. It discusses: how arbitrability of intellectual property rights disputes might improve worldwide IPR enforcement; how the “disregard of legal entity” may be used to establish implied consent by a person or entity that is not a signatory to an arbitration agreement; how an effective cross-border insolvency framework under the Indian insolvency and bankruptcy code can borrow from the UNCITRAL Model Law’s and other jurisdictions’ approaches to the tension between “universality” and “territoriality”; how a promising new mediation act for Pakistan may help resolve a backlog of millions of cases in a jurisdiction with a patchwork of traditional and modern alternative dispute resolution mechanisms; how the European Union seeks to balance the taxation of digital services; how Brazil is addressing the taxation of offshore indirect transfers; how private equity capital structures in the unique market of professional sports create opportunities as well as risks; how Securities Market Regulation theory plays a role in the organization and development of active securities markets, particularly in emerging markets; and how non-signatories can be bound by arbitration agreements in Brazil through “disregard of legal entity” to ascertain implied consent. The authors are practitioners and academics from Brazil, England, France, India, Pakistan, Singapore, the United States and Uzbekistan. They offer a broad and diverse perspective on some of today’s pressing business law issues in a shrinking world.
General Motors Corporation v Department of Treasury, 466 Mich 231 (2002)
Author: Official Congressional Directory 1999-2000
Author: Claitors LawPublisher: Official Congressional Directo
ISBN: 9781579804435
Category : Political Science
Languages : en
Pages : 1222
Book Description
Data Bases Available at the National Institute of Standards and Technology Research Information Center
Author: Diane CunninghamPublisher:
ISBN:
Category : Databases
Languages : en
Pages : 242
Book Description