Taxation Of Corporate Debt And Derivatives

Author : Julian Ghosh,Ian Johnson,Paul Miller
Publisher : Unknown
Page : 800 pages
File Size : 47,5 Mb
Release : 2009-04-14
Category : Electronic
ISBN : 1405747145

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Taxation of Corporate Debt and Derivatives by Julian Ghosh,Ian Johnson,Paul Miller Pdf

Formerly known as Taxation of Loan Relationships and Derivatives, this publication was re-launched and fully updated in April 2009. Offering invaluable tax planning help for the tax specialist and with its easy to use subject index and cross-referencing, Taxation of Corporate Debt and Derivatives is a highly practical publication, ideal for the busy tax practitioner and lawyer. Debt and Treasury management occupies an increasing proportion of the work of tax practitioners. With considerable legislation to get to grips with, this publication, updated twice per annum, offers a concise and comprehensive version of the law in this area. This publication examines, in detail, each of the regimes involving: * Foreign exchange transactions * Financial instruments (such as options, debt contracts, currency swaps) * Corporate debt, i.e. the loan relationship provisions * Anti-avoidance provisions including thin capitalisation, funding bonds etc

Author : Julian Ghosh
Publisher : Unknown
Page : 128 pages
File Size : 40,6 Mb
Release : 2009
Category : Corporate debt
ISBN : OCLC:373476801

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Ghosh, Johnson and Miller on the Taxation of Corporate Debt and Derivatives by Julian Ghosh Pdf

Author : David Southern,PricewaterhouseCoopers Foreign Exchange Tax Team
Publisher : Bloomsbury Professional
Page : 578 pages
File Size : 54,7 Mb
Release : 2004
Category : Bankruptcy
ISBN : 0754521192

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Tolley's Taxation of Corporate Debt, Foreign Exchange and Derivative Contracts by David Southern,PricewaterhouseCoopers Foreign Exchange Tax Team Pdf

Taxation of Corporate Debt, Foreign Exchange and Derivative Contracts Seventh Edition considers the practical implications of the legislation in loan relationships and derivative contracts made by the Finance Act 2002, and the related rules for foreign exchange. This comprehensive guide covers: * Changes in legislation and practice up to December 2003, including the Finance Act 2003 * FRED 23, 24 and 30 * The Pre-Budget Statement * All relevant legislation, cases and background information * Case law developments. This book also contains numerous worked examples explaining the interaction between tax codes, accounting framework, corporate transactions and various planning issues to aid further understanding of the material covered. Providing the answers to all your questions regarding corporate debt and derivative contracts, Taxation of Corporate Debt, Foreign Exchange and Derivative Contracts Seventh Edition includes: * Loan relationships: concepts and application, structured capital finance, debt securities and acquisitions and disposals * Foreign exchange: overview of the 1993 Finance Act tax regime, Finance Act 2002 and local currency companies * Derivative contracts: scope and definition, computation of profits and anti-avoidance rules* Stock lending and repos: detailed analysis of legislation including Finance Act 2003 changes. This is your complete reference source to planning and restructuring your financial transactions to avoid potential and unexpected tax liabilities.

Author : David Southern
Publisher : A&C Black
Page : 657 pages
File Size : 52,6 Mb
Release : 2012-06-01
Category : Business & Economics
ISBN : 9781845923037

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Taxation of Loan Relationships and Derivative Contracts by David Southern Pdf

The ninth edition of this well-established work offers comprehensive coverage of all aspect of the taxation of loan relationships and derivative contracts in the UK. It covers the UK's IAS 32/39 and FRS 25/26, loan relationships under IAS, impairment losses and connected company rules, the derivative contracts rules, bifurcation of convertibles, transfer pricing domestic and international, the disregard rules on tax hedging, matching and functional currencies, reconstructions and mergers, repos and stock lending, anti-avoidance rules, corporate debt, loan relationships, derivative contracts, securities taxation, and debt impairment. Particular emphasis is placed on providing worked examples and planning guidance.

Author : T. Rumble
Publisher : Springer
Page : 256 pages
File Size : 49,9 Mb
Release : 2002-12-03
Category : Business & Economics
ISBN : 9780230513143

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The Taxation of Equity Derivatives and Structured Products by T. Rumble Pdf

The taxation of equity derivatives and structured products is analyzed in detail by Tony Rumble and his contributors, Mohammed Amin and Ed Kleinbard. The book covers the financial and tax technical analysis of issues relating to equity derivatives and structured products. Part 1 examines the derivatives building blocks and financial market/corporate finance drivers of the equity derivatives and financial products market, and includes case studies of typical and landmark transactions. Part 2 looks at the tax technical rules in each of the target countries - the US, UK and Australia - and examines the specific products highlighted in the first part of the book. Case studies of significant transactions are included where necessary.

Author : David Southern
Publisher : Unknown
Page : 128 pages
File Size : 52,9 Mb
Release : 2001-12-30
Category : Electronic
ISBN : 0754512193

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Taxation of Corporate Debt and Financial Instruments by David Southern Pdf

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 : Antti Laukkanen
Publisher : IBFD
Page : 487 pages
File Size : 47,5 Mb
Release : 2007
Category : Bonds
ISBN : 9789087220228

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Taxation of Investment Derivatives by Antti Laukkanen Pdf

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 : David Southern
Publisher : Tolley
Page : 364 pages
File Size : 51,6 Mb
Release : 1998
Category : Bankruptcy
ISBN : 1860128548

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Tolley's Taxation of Corporate Debt and Financial Instruments by David Southern Pdf

This work draws together the taxation issues relating to debt instruments used in corporate finance and investment, and offers a complete guide through the maze of new legislation. It focuses on the practical implications of the Finance Act 1996 and also covers the interaction between taxes, the accounting framework, corporate transactions and planning issues.

Author : Julian Ghosh
Publisher : Unknown
Page : 128 pages
File Size : 46,6 Mb
Release : 2009
Category : Corporate debt
ISBN : OCLC:373476801

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Ghosh, Johnson and Miller on the Taxation of Corporate Debt and Derivatives by Julian Ghosh Pdf

Author : Pietro Dallari,Mr.Nicolas End,Fedor Miryugin,Alexander F. Tieman,Mr.Seyed Reza Yousefi
Publisher : International Monetary Fund
Page : 42 pages
File Size : 48,6 Mb
Release : 2018-12-07
Category : Business & Economics
ISBN : 9781484389102

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Pouring Oil on Fire: Interest Deductibility and Corporate Debt by Pietro Dallari,Mr.Nicolas End,Fedor Miryugin,Alexander F. Tieman,Mr.Seyed Reza Yousefi Pdf

This paper investigates the role of tax incentives towards debt finance in the buildup of leverage in the nonfinancial corporate (NFC) sector, using a large firm-level dataset. We find that so-called debt bias is a significant driver of leverage, for both small and medium-sized enterprises and larger firms, with its effect accounting for about a quarter of leverage. The strength of this effect differs with firm size, the availability of collateral, income and income volatility, cash flow, and capital intensity. We conclude that leveling the playing field between debt and equity finance through tax policy reform would decrease NFC leverage, reducing economic risks posited by leverage.

Author : Ms.Oana Luca,Alexander F. Tieman
Publisher : International Monetary Fund
Page : 28 pages
File Size : 52,6 Mb
Release : 2016-11-10
Category : Business & Economics
ISBN : 9781475552805

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Financial Sector Debt Bias by Ms.Oana Luca,Alexander F. Tieman Pdf

Most tax systems create a tax bias toward debt finance. Such debt bias increases leverage and may negatively affect financial stability. This paper models and estimates debt bias in the financial sector, and present novel estimates for investment banks and non-bank financial intermediaries such as finance and insurance companies. We find debt bias to be pervasive, explaining as much as 10 percent of total leverage for regular banks and 20 percent for investment banks, with the effects most pronounced before the global financial crisis. Going forward, debt bias is likely to once again gain prominence as a key driver of leverage decisions, underscoring the importance of policy reform at this juncture.

Author : Oktavia Weidmann
Publisher : Kluwer Law International B.V.
Page : 439 pages
File Size : 43,7 Mb
Release : 2015-07-16
Category : Law
ISBN : 9789041159830

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Taxation of Derivatives by Oktavia Weidmann Pdf

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 : John R. Graham
Publisher : Now Publishers Inc
Page : 136 pages
File Size : 52,5 Mb
Release : 2006
Category : Business & Economics
ISBN : 9781933019413

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A Review of Taxes and Corporate Finance by John R. Graham Pdf

A Review of Taxes and Corporate Finance investigates the consequences of taxation on corporate finance focusing on how taxes affect corporate policies and firm value. A common theme is that tax rules affect corporate incentives and decisions. A second emphasis is on research that describes how taxes affect costs and benefits. A Review of Taxes and Corporate Finance explores the multiple avenues for taxes to affect corporate decisions including capital structure decisions, organizational form and restructurings, payout policy, compensation policy, risk management, and the use of tax shelters. The author provides a theoretical framework, empirical predictions, and empirical evidence for each of these areas. Each section concludes with a discussion of unanswered questions and possible avenues for future research. A Review of Taxes and Corporate Finance is valuable reading for researchers and professionals in corporate finance, corporate governance, public finance and tax policy.

Author : Dearborn Financial Publishing
Publisher : Kaplan Publishing
Page : 0 pages
File Size : 40,6 Mb
Release : 2002-04
Category : Business & Economics
ISBN : 0793151910

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Taxation of Financial Products, 2e by Dearborn Financial Publishing Pdf

"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 : John Snape
Publisher : Bloomsbury Publishing
Page : 203 pages
File Size : 46,6 Mb
Release : 2011-12-09
Category : Law
ISBN : 9781847318718

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The Political Economy of Corporation Tax by John Snape Pdf

Excellent technical writing on corporation tax abounds, but it tends to be inaccessible to public lawyers, political theorists and political economists. Although recent years have seen not only an explosion in public law scholarship but also a reawakening of interest in interpretative political theory and political economy, the potential of these perspectives to illuminate the corporation tax debate has remained unexplored. In this important work, John Snape seeks to reconcile these disparate strands of scholarship and to contribute to a new way of understanding and conceptualising the reform of the law relating to corporate taxation. Drawing on important developments in public law scholarship, the study combines elements of political theory and political economy. It advances a new interpretation of corporation tax law as an instrument of rule, through the maximisation of a nation's economic potential. Snape shows how corporate taxation belongs at the centre of any discussion of economic globalisation, not only because of the potential of national tax systems to influence inward investment decisions but also because of the potential of those decisions to shape the public interest that those tax systems might embody. Following public law and politics models, the book looks afresh at the impact of Britain's political institutions, of the processes of its representative government and of the theory that moulds and orders the values that the corporation tax code contains. This is a timely exploration of cutting-edge issues of public policy.