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Author: Oktavia Weidmann Publisher: Kluwer Law International B.V. ISBN: 9041159835 Category : Law Languages : en Pages : 417
Book Description
The exploding use of derivatives in the last two decades has created a major challenge for tax authorities, who had to develop appropriate derivatives taxation rules that strike a balance between allowing capital markets to function effectively by removing artificial tax barriers and at the same time protecting their countries' tax base from tax avoidance schemes that utilise these instruments. Derivatives exist in a vast variety and complexity and new forms or combinations of existing forms appear ad hoc as new risk categories emerge and companies seek to invest in or hedge these risks. This very thorough book discusses and analyses taxation issues posed by derivatives used in domestic as well as in cross-border transactions. In great detail the author presents approaches that can be adopted by tax legislators to solve these problems, clarifying her solutions with specific reference to components of the two most important domestic tax systems in relation to derivatives in Europe, those of the United Kingdom and Germany. Examples of derivatives transactions and arbitrage schemes greatly elucidate the nature of derivatives and how they can be effectively taxed. The following aspects of the subject and more are covered: – basic economic concepts in the context of derivatives such as replication, put-call-parity, hedging and leverage; - designing a suitable definition of derivatives in domestic tax law; - achieving coherence in domestic tax rules by applying a 'special regime approach' versus an 'integrative approach' and the distinction of income and capital, equity and debt; - alignment of accounting standards and taxation rules and the application of fair value accounting for tax purposes; - how to tax hedged positions and post-tax hedging schemes; - taxation of structured financial products and hybrid instruments with focus on bifurcation and integration approaches and the recent BEPS discussion drafts on hybrid mismatch arrangements; - refining the 'beneficial ownership' – concept in domestic law and in tax treaties and an analysis of recent case law; - withholding taxes in the context of domestic and cross-border dividend tax arbitrage schemes; and - tackling derivatives tax arbitrage effectively in anti-avoidance legislation. By providing an in-depth analysis of corporate taxation issues that arise in domestic as well as in cross-border derivatives transactions, this book is not only timely but of lasting value in the day-to-day work of tax lawyers and tax professionals in companies, banks and funds, and is sure to be of interest to government officials, academics and researchers involved with financial instruments taxation.
Author: Oktavia Weidmann Publisher: Kluwer Law International B.V. ISBN: 9041159835 Category : Law Languages : en Pages : 417
Book Description
The exploding use of derivatives in the last two decades has created a major challenge for tax authorities, who had to develop appropriate derivatives taxation rules that strike a balance between allowing capital markets to function effectively by removing artificial tax barriers and at the same time protecting their countries' tax base from tax avoidance schemes that utilise these instruments. Derivatives exist in a vast variety and complexity and new forms or combinations of existing forms appear ad hoc as new risk categories emerge and companies seek to invest in or hedge these risks. This very thorough book discusses and analyses taxation issues posed by derivatives used in domestic as well as in cross-border transactions. In great detail the author presents approaches that can be adopted by tax legislators to solve these problems, clarifying her solutions with specific reference to components of the two most important domestic tax systems in relation to derivatives in Europe, those of the United Kingdom and Germany. Examples of derivatives transactions and arbitrage schemes greatly elucidate the nature of derivatives and how they can be effectively taxed. The following aspects of the subject and more are covered: – basic economic concepts in the context of derivatives such as replication, put-call-parity, hedging and leverage; - designing a suitable definition of derivatives in domestic tax law; - achieving coherence in domestic tax rules by applying a 'special regime approach' versus an 'integrative approach' and the distinction of income and capital, equity and debt; - alignment of accounting standards and taxation rules and the application of fair value accounting for tax purposes; - how to tax hedged positions and post-tax hedging schemes; - taxation of structured financial products and hybrid instruments with focus on bifurcation and integration approaches and the recent BEPS discussion drafts on hybrid mismatch arrangements; - refining the 'beneficial ownership' – concept in domestic law and in tax treaties and an analysis of recent case law; - withholding taxes in the context of domestic and cross-border dividend tax arbitrage schemes; and - tackling derivatives tax arbitrage effectively in anti-avoidance legislation. By providing an in-depth analysis of corporate taxation issues that arise in domestic as well as in cross-border derivatives transactions, this book is not only timely but of lasting value in the day-to-day work of tax lawyers and tax professionals in companies, banks and funds, and is sure to be of interest to government officials, academics and researchers involved with financial instruments taxation.
Author: Pete Miller Publisher: Bloomsbury Publishing ISBN: 1526511517 Category : Business & Economics Languages : en Pages : 749
Book Description
Taxation of Company Reorganisations, Sixth Edition is an essential reference source for tax advisers which covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions. Written by authors with more than fifty years' experience of dealing with clients from small owner-managed businesses to multinational corporate groups, this title includes guidance on the full range of corporate transactions and is applicable to a wide number of organisations. While there is comprehensive coverage of the technical and theoretical meaning of the legislation, the authors have also drawn on their vast practical experience, derived from many years of transaction-based work. This Sixth Edition has been brought fully up to date with recent Finance Acts including FA 2019 and the proposals for FA 2020 that were published in July 2019. It has been reviewed for company and European law and has been updated in relation to the following: - Changes to substantial shareholding exemptions in Finance (No. 2) Act 2017 - Changes to EIS, SEIS and VCT investment schemes in FA 2018 - The introduction of LBTT in Scotland and LTT in Wales - Stamp duty changes proposed for FA 2020 - Enhanced material on the taxation of goodwill and loan relationships on a reorganisation Cases updated since the last edition include: - Gallaher Ltd v Revenue and Customs Commissioners [2019] UKFTT 207 (TC) (on application of s171 TCGA 1992) - Hancock [2019] 1 WLR 3409 (Supreme Court decision) - Trigg [2018] EWCA Civ 17 (Court of Appeal decision)
Author: Kevin Walton (Engineer) Publisher: ISBN: 9780754546467 Category : Capital gains tax Languages : en Pages :
Book Description
Tolley's Capital Gains Tax provides the definitive, yet straightforward, concise account of the law and practice relating to this complex tax. Corporation tax on chargeable gains is also fully covered. the practical alphabetical presentation and extensive cross-referencing between chapters, backed up by full details of source materials, will lead directly to all the information the tax practitioner requires.
Author: Alexis Madrigal Publisher: Da Capo Press ISBN: 0306819775 Category : Science Languages : en Pages : 386
Book Description
Few today realize that electric cabs dominated Manhattan's streets in the 1890s; that Boise, Idaho, had a geothermal heating system in 1910; or that the first megawatt turbine in the world was built in 1941 by the son of publishing magnate G. P. Putnam -- a feat that would not be duplicated for another forty years. Likewise, while many remember the oil embargo of the 1970s, few are aware that it led to a corresponding explosion in green-technology research that was only derailed when energy prices later dropped. In other words: We've been here before. Although we may have failed, America has had the chance to put our world on a more sustainable path. Americans have, in fact, been inventing green for more than a century. Half compendium of lost opportunities, half hopeful look toward the future, Powering the Dream tells the stories of the brilliant, often irascible inventors who foresaw our current problems, tried to invent cheap and energy renewable solutions, and drew the blueprint for a green future.
Author: Kevin Walton Publisher: ISBN: 9780754541929 Category : Capital gains tax Languages : en Pages : 1750
Book Description
Tolley’s Capital Gains Tax provides the definitive, yet straightforward, concise account of the law and practice relating to this complex tax. Corporation tax on chargeable gains is also fully covered.Its practical alphabetical presentation and extensive cross-referencing between chapters, backed up by full details of source materials, will lead you directly to all the information you want.Price includes a post-Budget 2011 Supplement published in April and a full edition post-Finance Act 2011 published in September (also available separately).
Author: Jonathan Reuvid Publisher: Legend Press ISBN: 1908775548 Category : Business & Economics Languages : en Pages : 382
Book Description
Investors' Guide to the United Kingdom highlights the positive features and practical benefits that continue to make the UK an attractive location for foreign investors. Key industry and services sectors and their business outlooks are profiled in the context of the Government's economic development programme and incentives for industry. These chapters are authored by the editor based on reports and data provided by the private sector, government ministries and agencies, principally the Ministry of Business, Industry and Skills. This is the fifth edition of the vital guide for foreign investors.
Author: Gio Wiederhold Publisher: Springer Science & Business Media ISBN: 1461466113 Category : Business & Economics Languages : en Pages : 602
Book Description
Valuing Intellectual Capital provides readers with prescriptive strategies and practical insights for estimating the value of intellectual property (IP) and the people who create that IP within multinational companies. This book addresses the crucial topic of taxation from a rigorous and quantitative perspective, backed by experience and original research that illustrates how large corporations need to measure the worth of their intangible assets. Each method in the text is applied through the lens of a model corporation, in order for readers to understand and quantify the operation of a real-world multinational enterprise and pinpoint how companies easily misvalue their intellectual capital when transferring IP rights to offshore tax havens. The effect contributes to the issues that can lead to budgetary crises, such as the so-called “fiscal cliff” that was partially averted by passage of the American Taxpayer Relief Act on New Year’s day 2013. This book also features a chapter containing recommendations for a fair and balanced corporate tax structure free of misvaluation and questionable mechanisms. CFOs, corporate auditors, corporate financial analysts, corporate financial planners, economists, and journalists working with issues of taxation will benefit from the concepts and background presented in the book. The material clearly indicates how a trustworthy valuation of intellectual capital allows a realistic assessment of a company’s income, earnings, and obligations. Because of the intense interest in the topic of corporate tax avoidance the material is organized to be accessible to a broad audience.
Author: Glen Loutzenhiser Publisher: Bloomsbury Publishing ISBN: 1509921354 Category : Law Languages : en Pages : 1647
Book Description
This is the ninth edition of John Tiley's major text on revenue law, covering the UK tax system, income tax, capital gains tax and inheritance tax, as well as incorporating sections dealing with corporation tax, international and European tax, savings and charities. This new edition is fully revised and updated with the latest case law, statutory and other developments, including Finance Act 2019. The book is designed for law students taking the subject in the final year of their law degree, or for more advanced courses, and is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but also to include citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems. Copy the URL below to read a 2021 supplement highlighting new developments since the book's publication in 2019: https://www.bloomsbury.com/media/2v1ej5vw/tileys-revenue-law-supplement-2021.pdf
Author: Paul B. Beers Publisher: Midtown Scholar Press ISBN: 9780983957102 Category : History Languages : en Pages : 0
Book Description
In City Contented, City Discontented: A History of Modern Harrisburg, award-winning journalist Paul Beers (1931-2011) reveals how contemporary Harrisburg came to be what it is. In a masterful series of essays, Beers charts the capital's development from a City Beautiful, with its celebrated public spaces and premier educational institutions, through the fractures of race riots and the catastrophic challenges of flood and near-nuclear meltdown. Beers employs the well-honed skills of a veteran reporter to craft fascinating character sketches of prominent leaders and humble citizens alike, intertwining their dramatic personal stories with a compelling survey of the region's society, politics, and culture in the twentieth century.
Author: Oktavia Weidmann
Author: Oktavia Weidmann
Author: Pete Miller
Author: Kevin Walton (Engineer)
Author: Alexis Madrigal
Author: Kevin Walton
Author: Jonathan Reuvid
Author: Anne Redston
Author: Gio Wiederhold
Author: Glen Loutzenhiser
Author: Paul B. Beers