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Press coverage has often shown little understanding of the distinction between tax avoidance and tax evasion, describing the legitimate behaviour of taxpayer banks, financial institutions and multinational businesses in emotive terms and often inaccurately. This book aims to look at tax arbitrage, and demystify its practice.
Tax Arbitrage Through Cross-border Financial Engineering by Gaspar Lopes Dias V.S. Pdf
This book explores tax arbitrage opportunities resulting from financial engineering techniques with cross-border financial instruments such as hybrids, synthetics, and non-traditional financial instruments. Firstly the author clarifies the concept of three kinds of complex financial instruments, and thereafter he discusses the most adequate tax treatment of these instruments in cross-border situations. For this purpose he identifies economic substance as an objective benchmark for the taxation of financial instruments to achieve greater international tax neutrality, and examines the role of the expected return taxation theory. The book also contains a comparative analysis of relevant developments in a number of jurisdictions, including Australia, Belgium, Brazil, Luxembourg, Portugal, UK and USA.
Frederic L. Ballard,Vicky Tsilas,Kimberly C. Betterton
Author : Frederic L. Ballard,Vicky Tsilas,Kimberly C. Betterton Publisher : American Bar Association Section of State and Local Government Law Page : 412 pages File Size : 45,6 Mb Release : 2018 Category : Electronic books ISBN : 1641050632
Author : Frederic L. Ballard Publisher : American Bar Association Page : 404 pages File Size : 45,7 Mb Release : 2007 Category : Business & Economics ISBN : 159031798X
Tax Planning with Holding Companies - Repatriation of US Profits from Europe by Rolf Eicke Pdf
The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
Sports Arbitrage - How to Place Riskless Bets & Create Tax-Free Investments by Rajeev Shah Pdf
This is the most detailed & comprehensive book available on the subject of sports-arbitrage. It has been written by an expert, with 15 years of trading experience, who sets out towards two goals: to teach the novice reader all there is to know before embarking on his or her sports-arbitrage trading project, and to teach experienced traders some of the more complex techniques used by professionals. Over 100 pages of this book are devoted to divulging methods to find arbitrage opportunities manually and, by using many real-world examples of trades, the author reveals & explains several techniques which have never before been published and which are as yet unknown to the majority of traders. The theories are explained clearly but what really sets this book apart is its focus on the practical realities of trading. Whether you are a novice or experienced trader, the author's insights will help you towards increased profits from your sports-arbitrage trading project.
Hybrid Financial Instruments in International Tax Law by Jakob Bundgaard Pdf
Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity. Focusing on hybrid financial instruments (HFIs) – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – this book analyses their treatment under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered. Advocating for a broader scope of application of HFIs as part of the financing of companies in Europe alongside traditional sources of debt and equity financing, the book addresses such issues and topics as the following: • problems associated with the debt-equity distinction in international tax law; • cross-border tax arbitrage and linking rules; • drivers behind the use and design of HFIs; • tax law impact of perpetual and super maturity debt instruments, profit participating loans, convertible bonds, mandatory convertible bonds, contingent convertibles, preference shares and warrant loans on HFIs; • financial accounting treatment; • administrative guidance; • influence of the TFEU on Member States’ approaches to classification of HFIs; • interpretation of the Parent-Subsidiary Directive by the European Court of Justice; • applicability of the OECD Model Tax Convention; and • implications of the OECD Base Erosion and Profit Shifting (BEPS) project. Throughout this book, the analysis draws upon preparatory works, case law, and legal theory in English, German, and the Scandinavian languages. In conclusion, the author considers tax policy issues, and identifies and outlines possible high-level solutions. Actual or potential users of HFIs will greatly appreciate the clarity and insight offered here into the capacity and tax implications of HFIs. The book not only examines whether existing legislation is sufficient to handle the issues raised by international HFIs, but also provides an in-depth analysis of the interaction between corporate financing and tax law in the light of today’s financial innovation. Corporate executives and their counsel will find it indispensable in the international taxation landscape that is currently coming into view, and academics and policymakers will hugely augment their understanding of a complex and constantly changing area of tax law.
Author : John B. Shoven,John Whalley Publisher : University of Chicago Press Page : 400 pages File Size : 48,5 Mb Release : 2007-12-01 Category : Business & Economics ISBN : 9780226754826
Canada-U.S. Tax Comparisons by John B. Shoven,John Whalley Pdf
In the increasingly global economy, domestic tax policies have taken on a new importance for international economics. This unique volume compares the tax reform experiences of Canada and the United States, two countries with the world's largest bilateral flow of trade and investment. With the signing of the U.S.-Canada Free Trade Agreement and the tax reforms of the 1980s, there has been some harmonization of tax systems. But geographic, cultural, and political characteristics shape distinct national social policies that may impede harmonization. As the U.S. and Canadian economies become even more integrated, differences in tax systems will have important effects, in particular on the relative rates of economic growth. In this timely study, scholars from both countries show that, while the United States and Canada exhibit similar corporate tax structures and income tax systems, they have very different approaches to sales tax and social security taxes. Despite these differences, the two countries generate roughly the same amounts of revenue, produce similar costs of capital, and produce comparable distributions of income.
Hybrid Entities in Tax Treaty Law by Sriram Govind,Jean-Philippe Van West Pdf
Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.
Options to Improve Tax Compliance and Reform Tax Expenditures by United States. Congress. Joint Committee on Taxation Pdf
Describes proposals to to reduce the size of the Federal tax gap by curtaling tax shelters, closing unintended loopholes, addressing other areas of noncompliance with current tax law, and reforming certain areas of tax expenditures.
