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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.
Taxation of Equity Derivatives by Sam Chen,Paul J. Kunkel Pdf
" ... analyzes the tax consequences of transactions involving equity derivatives. After discussing "traditional" equity derivatives, the portfolio discusses more "modern" equity derivatives that have arisen in recent years. The portfolio then turns to a discussion of special issues that arise when corporations take positions in their own stock."
Taxation of Non-equity Derivatives by L. G. Harter (Lawyer),Michael Lukacs,David Shurberg,Tax Management Inc,Bloomberg BNA. Pdf
... reviews the U.S. federal income taxation of derivative transactions other than equity derivatives. The taxation of equity derivatives is reviewed in a separate portfolio. See 188 T.M., Taxation of Equity Derivatives. This Portfolio is divided into eight main parts.
Author : Frank J. Fabozzi, CFA Publisher : John Wiley & Sons Page : 320 pages File Size : 47,6 Mb Release : 1998-06-20 Category : Business & Economics ISBN : 1883249554
The Use of Derivatives in Tax Planning by Frank J. Fabozzi, CFA Pdf
The Use of Derivatives in Tax Planning provides insightful and in-depth coverage of timely issues including: tax treatments of notional principal contracts, taxation of credit derivatives, derivative tax planning applications for fixed-income instruments, using derivatives to shift income, enhancing after-tax returns, working with the straddle rules of tax code sections 1092 and 263(g), derivatives in the charitable world, using OTC equity derivatives for high-net-worth individuals, corporate applications of derivatives, synthetic exchangeables and convertibles, and structures and selected tax issues.
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.
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.
Jack Clark Francis,William W. Toy,J. Gregg Whittaker
Author : Jack Clark Francis,William W. Toy,J. Gregg Whittaker Publisher : John Wiley & Sons Page : 742 pages File Size : 51,8 Mb Release : 1999-11-08 Category : Business & Economics ISBN : 0471326038
The Handbook of Equity Derivatives by Jack Clark Francis,William W. Toy,J. Gregg Whittaker Pdf
Aktienderivate gehören zu den populärsten Derivatprodukten, die von institutionellen Anlegern gehandelt werden. Ein Aktienderivat ist ein Future oder eine Option auf Aktien oder Aktienindices. Zu den traditionellen Aktienderivaten gehören Optionsscheine, Optionen, Futures und Aktienindexfutures. Das "Handbook of Equity" ist eine vollständige und umfassende Überarbeitung des ersten und einzigen Buches zu diesem Thema. Herausgegeben von führenden Köpfen der Branche - darunter Nobelpreisträger Fischer Black, John Braddock und Mark Rubenstein - enthält es wichtige neue Informationen zu Aktienindexfutures und -optionen und erweitert die mathematische Diskussion um das Black & Scholes-Modell. (11/99)
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.
Stochastic Discounted Cash Flow by Lutz Kruschwitz,Andreas Löffler Pdf
This open access book discusses firm valuation, which is of interest to economists, particularly those working in finance. Firm valuation comes down to the calculation of the discounted cash flow, often only referred to by its abbreviation, DCF. There are, however, different coexistent versions, which seem to compete against each other, such as entity approaches and equity approaches. Acronyms are often used, such as APV (adjusted present value) or WACC (weighted average cost of capital), two concepts classified as entity approaches. This book explains why there are several procedures and whether they lead to the same result. It also examines the economic differences between the methods and indicates the various purposes they serve. Further it describes the limits of the procedures and the situations they are best applied to. The problems this book addresses are relevant to theoreticians and practitioners alike.
General Explanation of Tax Legislation Enacted in ... by Anonim Pdf
JCS-5-05. Joint Committee Print. Provides an explanation of tax legislation enacted in the 108th Congress. Arranged in chronological order by the date each piece of legislation was signed into law. This document, prepared by the staff of the Joint Committee on Taxation in consultation with the staffs of the House Committee on Ways and Means and the Senate Committee on Finance, provides an explanation of tax legislation enacted in the 108th Congress. The explanation follows the chronological order of the tax legislation as signed into law. For each provision, the document includes a description of present law, explanation of the provision, and effective date. Present law describes the law in effect immediately prior to enactment. It does not reflect changes to the law made by the provision or subsequent to the enactment of the provision. For many provisions, the reasons for change are also included. In some instances, provisions included in legislation enacted in the 108th Congress were not reported out of committee before enactment. For example, in some cases, the provisions enacted were included in bills that went directly to the House and Senate floors. As a result, the legislative history of such provisions does not include the reasons for change normally included in a committee report. In the case of such provisions, no reasons for change are included with the explanation of the provision in this document. In some cases, there is no legislative history for enacted provisions. For such provisions, this document includes a description of present law, explanation of the provision, and effective date, as prepared by the staff of the Joint Committee on Taxation. In some cases, contemporaneous technical explanations of certain bills were prepared and published by the staff of the Joint Committee. In those cases, this document follows the technical explanations. Section references are to the Internal Revenue Code unless otherwise indicated.
Taxation of Loan Relationships and Derivative Contracts by David Southern Pdf
Taxation of Loan Relationships and Derivative Contracts, Tenth Edition, is updated in line with the Finance Act 2015 which brings in significant changes to the loan relation rules. In addition, it includes changes to both UK and International Accounting Standards. This new edition covers developments in the Basic Erosion and Profit Shifting (BEPs) project and the related new climate and wider concept of tax avoidance (GAAR). The chapters covering accounting framework, reorganisations and international aspects have been significantly updated since the previous edition and new chapters have been added with a summary of all relevant cases and a chapter covering Islamic Finance. Covers the following: The Taxation of Finance Accounting under IFRS and Modified UK GAAP The Scheme of the Legislation Loan Relationships: Scope and Definition Loan Relationships: General Computational Provisions Loan Relationships: Special Computational Provisions Impairment Losses Foreign Exchange and Hedging/Deferral Interest Securities Reorganisations, Acquisitions and Disposals Special Companies Derivative Contracts – Definition and Scope Derivative Contracts – Measurement of Profits Embedded Derivatives Worldwide Debt Cap Transfer Pricing Stock Lending and Repos International Aspects Islamic Finance Cases Appendices
The US is the world's largest capital market. Its withholding tax system is also the most complex. This book is essential reading for investors and intermediaries trying to comply with US QI and FATCA tax regulations. It guides the reader through these complex regulations with simple and practical insights into how to meet these compliance burdens.
The International Tax Law Concept of Dividend by Marjaana Helminen Pdf
The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
