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Author : Henry D. Shereff
Publisher : Unknown
Page : 424 pages
File Size : 51,9 Mb
Release : 1990
Category : Business & Economics
ISBN : UCAL:B4316281
Author : Organisation for Economic Co-operation and Development
Publisher : OECD
Page : 128 pages
File Size : 55,7 Mb
Release : 1994
Category : Business & Economics
ISBN : STANFORD:36105016365590
Presents the results of an analysis of the application of domestic laws and tax treaties to four particular types of instruments: interest rate swaps, financial futures, options to by shares, and bonds issued at a deep discount. Explores the possibility of arriving at consistent treatment of these instruments to provide greater certainty for both tax administrators and the financial markets.
Author : Arlene Mary Hibschweiler,Marion Kopin
Publisher : McGraw Hill Professional
Page : 478 pages
File Size : 55,7 Mb
Release : 2003
Category : Business & Economics
ISBN : 0071396969
Publisher Description
Author : Félix Daniel Martínez Laguna
Publisher : Kluwer Law International B.V.
Page : 685 pages
File Size : 54,5 Mb
Release : 2019-06-12
Category : Law
ISBN : 9789403510842
Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.
Author : Anonim
Publisher : Unknown
Page : 0 pages
File Size : 53,6 Mb
Release : 1991
Category : International business enterprises
ISBN : OCLC:24818893
Author : Mr.John R. King,Mr.Vito Tanzi
Publisher : International Monetary Fund
Page : 32 pages
File Size : 40,9 Mb
Release : 1995-05-01
Category : Business & Economics
ISBN : 9781451846515
Taxes affect the degree and efficiency of financial intermediation in many different ways. This paper summarizes the main tax provisions in OECD countries that affect the overall “tax wedge” between pre-tax returns on investments, and the post-tax yield on the savings that finance them. This tax wedge is shown to vary widely, in individual countries, according to the different ways in which savings are channeled through financial markets. The paper then discusses alternative criteria for assessing tax regimes for financial assets, and summarizes recent trends in OECD countries.
Author : Timothy Edgar,Canadian Tax Foundation
Publisher : Canadian Tax Foundation = L'Association canadienne d'études fiscales
Page : 645 pages
File Size : 45,7 Mb
Release : 2000
Category : Financial instruments
ISBN : 0888081588
Examines the theoretical and practical aspects of the treatment of financial instruments under a realisation-based income tax. Argues that, within such a context, a system of expected-return taxation in preferable. The argument is developed through a review of the academic literature and selected legislative regimes.
Author : Antti Laukkanen
Publisher : IBFD
Page : 487 pages
File Size : 47,7 Mb
Release : 2007
Category : Bonds
ISBN : 9789087220228
This dissertation aims to provide a comprehensive overview of the taxation of investment derivatives and the relationship between the derivatives and the accrual and realization methods. Investment derivatives, such as convertible bonds, include an initial investment and a derivative (an option) to buy or sell or to participate in the value movements of some underlying property. The principal focus of this study is on three universal tax issues, namely valuation, timing and the taxation of unrealized gains. As a common principle, interest income and capital gains are treated more similarly in corporate taxation than in individual taxation. Moreover, the taxation of financial instruments is currently in a turn-around phase in several countries, not least because of the implementation of the IFRS rules in accounting and the related fair value principle. The obligation to use fair values in accounting apparently motivates tax legislators to strive to use the same principles in taxation as well. The comparative method plays a major role in this study by examining the tax legislations and the tax practices of different countries. An in-depth analysis of the similarities and differences of tax laws and practices in the United States, the United Kingdom, Germany, Finland and Sweden is provided. This is of particular interest as the underlying components, single and often specified financial derivatives, are basically identical. While this study does not deal with individual tax treaties or bilateral transactions, the OECD Model is scrutinized in order to highlight the underlying principles of the given recommendations, especially with respect to interest income and capital gains. Due to the increasing importance of IFRS rules in accounting, the study is not limited to tax law, but also looks at issues from the perspective of finance, accounting and economics.
Author : OECD
Publisher : OECD Publishing
Page : 71 pages
File Size : 47,7 Mb
Release : 1998-03-09
Category : Electronic
ISBN : 9789264162495
This publication thoroughly reviews the factual background to global trading, analyses the challenges posed to traditional taxation methods and discusses a range of policy options to tackle the problems.
Author : G. M. M. Michielse
Publisher : Springer
Page : 376 pages
File Size : 40,9 Mb
Release : 1996-04-17
Category : Business & Economics
ISBN : STANFORD:36105060464877
General overview of the tax treatments of various financial instruments in four important EC Member States: France, Germany, the Netherlands and the United Kingdom, showing the most important tax differences and outlining the points on which EC harmonization is the most imperative, but also the most difficult to realize.
Author : Dearborn Financial Publishing
Publisher : Kaplan Publishing
Page : 0 pages
File Size : 55,9 Mb
Release : 2002-04
Category : Business & Economics
ISBN : 0793151910
"Taxation of Financial Products is designed for all financial services professionals.It explains the basics of selected financial products and their income tax treatment.Chapters focus on federal income tax basics, mutual funds, annuities, stocks, bonds, life insurance and qualified plans.The information provided is comprehensive and up to date with current tax laws and figures, as well as planning strategies."Taxation of Financial Products is written in plain English, and provides the financial services professional with the proper information needed to help meet clients' financial objectives. Material has been updated to reflect the changes made by the new distribution rules and the Tax Act of 2001, including updates to rules governing qualified plans, catch up contributions and simplification of required minimum distribution rules, and facts, figures, illustrations and examples have been updated. If you are taking this course for CE, the CE exam will automatically be added to your basket when selecting CE credit.Certain states require that a proctor/monitor supervise the exam taking process.
Author : Jeremy Bradburne,L. Anthony Joseph,Bruce Kayle,Masatami Otsuka,Gregory May
Publisher : Unknown
Page : 288 pages
File Size : 43,7 Mb
Release : 1994
Category : Business & Economics
ISBN : STANFORD:36105060983751
Thorough treatment of international taxation aspects of financial instruments. The treatment covers general US tax principles, equities, debt securities and derivatives and other financial instruments.
Author : Jeremy Bradburne
Publisher : Unknown
Page : 536 pages
File Size : 54,5 Mb
Release : 1989
Category : Bonds taxation
ISBN : UCSD:31822005230206
Author : Andrea S. Kramer,Nicholas Mowbray
Publisher : Unknown
Page : 128 pages
File Size : 50,7 Mb
Release : 2021-12-30
Category : Electronic
ISBN : 0808056719
Now in its fourth edition, this two-volume bound book provides a road map to work one's way through the tax and regulatory maze of financial products. It details the policies, rules, and interpretations that govern the federal regulation and taxation of securities, crypto currencies, commodities, options, derivatives, and hybrid products. It provides reliable answers to questions about financial markets, financial products, and market participants, and it will help with planning transactions and defending challenged tax positions.
Author : Jeremy Bradburne,Nicholas Noble,Geoffrey Pennells,Tony Joseph,Gregory May,Masatami Otsuka,Kenju Watanabe
Publisher : MICHIE
Page : 128 pages
File Size : 44,8 Mb
Release : 1994
Category : Electronic
ISBN : 0406003653
This text explains the way in which the rules have developed and examines the underlying concepts of current tax practice and legislation. It provides commentary on the tax treatment of the broad range of equity, debt and derivative transactions which regularly occur in the UK, US and Japan.