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Author : Anonim
Publisher : Unknown
Page : 109 pages
File Size : 52,6 Mb
Release : 2008
Category : Corporate reorganizations
ISBN : 0906524903
Author : K. A. Siobhan Monaghan
Publisher : Unknown
Page : 751 pages
File Size : 54,8 Mb
Release : 2012
Category : Consolidation and merger of corporations
ISBN : 0779851846
Author : Pete Miller,George Hardy,Fehzaan Ismail
Publisher : Bloomsbury Professional
Page : 0 pages
File Size : 52,7 Mb
Release : 2020-11-11
Category : Business & Economics
ISBN : 1526511495
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 : Domingo J. Jiménez-Valladolid de l'Hotellerie Fallois
Publisher : Unknown
Page : 442 pages
File Size : 53,8 Mb
Release : 2013
Category : Consolidation and merger of corporations
ISBN : 9087222270
Reorganization Clauses in Tax Treaties' analyses the tax consequences of corporate reorganizations in the context of tax treaty models and the solutions adopted in the global tax treaties network. The book also proposes solutions to be implemented in the model tax treaties in order to deal with cross-border reorganizations.0 Taxation of mergers and corporate reorganizations is often regarded as one of the most complex aspects of developed tax systems. Contrary to the general realization principle, transfers of assets and liabilities in the course of corporate reorganizations are not taxed when they occur. Instead, recognition of the capital gains arising from such transfers is deferred through different mechanisms under preferential tax regimes with the objective of granting corporate reorganizations a tax neutral treatment.0 However, this tax neutrality might be jeopardized when the effects of corporate reorganizations cross borders. So long as tax treaties do not cater for any special provisions dealing with the effects of corporate reorganizations, cross-border reorganizations will be hampered with the risks of overtaxation, while at the same time global tax neutrality will be compromised due to the inconsistent tax treatment of these transactions from a cross-border perspective.0 Only a few countries have dealt with issues originating from cross-border reorganizations in their tax treaty network. Nonetheless, the solutions adopted in the current situation do not provide satisfactory results when analysing the tax consequences of corporate reorganizations from a global perspective.
Author : PETE. HARDY MILLER (GEORGE.),George Hardy (Ph. D.)
Publisher : Unknown
Page : 672 pages
File Size : 42,5 Mb
Release : 2019
Category : Corporate reorganizations
ISBN : 1526511525
Author : Anonim
Publisher : Unknown
Page : 0 pages
File Size : 40,8 Mb
Release : 2010
Category : Corporate reorganizations
ISBN : 0779822870
Author : John B. Shoven,Joel Waldfogel
Publisher : Brookings Institution Press
Page : 228 pages
File Size : 54,8 Mb
Release : 2012-01-01
Category : Business & Economics
ISBN : 0815714262
The boom in corporate restructuring, accompanied by large increases in debt finance, was one of the most important developments in the U.S. economy in the 1980s. Financial and tax specialists analyze how the U.S. tax system-especially in its bias toward debt financing-has affected corporate financial decisions and influenced the recent wave of corporate restructuring. The authors evaluate the hypothesis that the rise in the cost of capital during the 1980s helped stimulate the surge in corporate takeovers. They analyze the effect that changes in tax laws and in the volume of government debt have had on corporate financial decisions. The authors examine how recent financial innovations have blurred the distinction between debt and equity finance.
Author : Pete Miller,George Hardy
Publisher : Bloomsbury Professional
Page : 450 pages
File Size : 43,6 Mb
Release : 2007
Category : Business & Economics
ISBN : 1845922530
Pete Miller's and George Hardy's new book offers an expert analysis of the key legislation and describes the historical development of the tax rules, their changing purpose, and the consequence of their application to commercial transactions. The practical day-to-day aspects are considered throughout.
Author : Eric Tomsett,Nicholas Noble
Publisher : Butterworths
Page : 128 pages
File Size : 42,8 Mb
Release : 1994-12-31
Category : Electronic
ISBN : 0406035962
The tax implications of company reorganization are likely to be of great complexity. This book explains the principal considerations arising from the types of reorganizations undertaken by both UK and international corporations, and it adopts a transaction-based approach to the subject. The material relating to domestic reorganizations is arranged under six main headings - share reorganizations, mergers and amalgamations, reconstructions, de-mergers, management buy-outs and reorganizations before a sole purchase of own shares. This is followed by an examination of international reorganizations, as applicable to UK companies operating overseas and to overseas companies operating in the UK.
Author : Daniel M. Schneider,Paul E. Hoelschen
Publisher : Shepard's/McGraw-Hill
Page : 834 pages
File Size : 44,8 Mb
Release : 1988
Category : Business & Economics
ISBN : STANFORD:36105063840537
This volume explores the seven types of reorganizations and their variations. Also covered are such topics as the relationship of S Corporations to reorganizations, foreign reorganizations, liquidations, poison pills, estate freezes and original issue and market discounts.
Author : Richard Fisher Peirce
Publisher : Unknown
Page : 328 pages
File Size : 51,7 Mb
Release : 1955
Category : Electronic
ISBN : UIUC:30112064707679
Author : Anonim
Publisher : Unknown
Page : 236 pages
File Size : 55,6 Mb
Release : 1972
Category : Consolidation and merger of corporations
ISBN : STANFORD:36105044141351
Author : Federated Press
Publisher : Unknown
Page : 128 pages
File Size : 48,5 Mb
Release : 2008
Category : Electronic
ISBN : 1554633516
Author : Stephen Schwarz,Daniel J. Lathrope
Publisher : Ingram
Page : 0 pages
File Size : 52,8 Mb
Release : 2016
Category : Corporations
ISBN : 1634596021
The ninth edition of this widely used casebook continues its long tradition of teaching the "fundamentals" of a highly complex subject with clear and engaging explanatory text, skillfully drafted problems, and a rich mix of original source materials to accompany the Code and regulations. Important highlights of the ninth edition include: Coverage of all significant developments since the last edition, including the impact on corporate-shareholder transactions of the now permanent higher marginal individual tax rates and the 3.8% tax on net investment income tax; final regulations on § 336(e) elections and Type F reorganizations; published rulings on internal corporate restructuring transactions; new legislation blocking tax-free spin-offs of REITs and the IRS's no-ruling policy on certain other types of cash-rich corporate divisions; and S corporation developments. Updated discussion of the options and prospects for fundamental corporate tax reform, including an overview of issues affecting U.S. multinational corporations. Reorganized discussion of the continuity of proprietary interest doctrine in tax-free reorganizations. Expanded coverage of the § 1202 exclusion for sales of small business stock and compensation issues for S corporation owner-employees. Removal of dated and historical materials and more tightly edited cases.
Author : Joseph W. Bartlett
Publisher : John Wiley & Sons
Page : 534 pages
File Size : 43,8 Mb
Release : 1991
Category : Business & Economics
ISBN : STANFORD:36105044518103