Taxation Of Loan Relationships And Derivative Contracts
Taxation Of Loan Relationships And Derivative Contracts Book in PDF, ePub and Kindle version is available to download in english. Read online anytime anywhere directly from your device. Click on the download button below to get a free pdf file of Taxation Of Loan Relationships And Derivative Contracts book. This book definitely worth reading, it is an incredibly well-written.
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.
Taxation of Loan Relationships and Derivative Contracts - Supplement to the 10th edition by David Southern Pdf
Brings the reader right up-to-date with the latest tax changes affecting loan relationships and derivative contracts. Taxation of Loan Relationships and Derivative Contracts - Supplement to the 10th Edition gives detailed coverage with working examples of the major legislative changes that have been introduced in these areas since the publication of the 10th edition in 2017. It contains chapters dealing with:
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.
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
Classifying Entities and the Meaning of 'Tax Transparency' by Michael McGowan Pdf
Imposing UK tax on an entity or those linked to it involves understanding what kind of entity is being dealt with, especially when it is formed outside the UK. Is it a company, a partnership, a trust or something else? This often involves considering whether the entity is ‘tax transparent’ and if so, what that means. While of great importance, the UK tax rules for classifying entities are notoriously vague, as is the UK meaning of ‘tax transparency’. This book breaks new ground by exploring these topics comprehensively, in a world which is well aware of the problems created by entity classification mismatches. In so doing, it addresses, with emphasis on UK tax law, issues such as: the meaning of a ‘partnership’ and a ‘trust’; what is meant and is not meant by ‘tax transparency’, across a range of taxes and situations; how tax treaties have dealt with entity classification questions and related ‘transparency’ issues; how entity classification questions are impacted by EU law; and how the UK approach could be improved, policy-wise and practically, without facilitating tax avoidance. The book compares in detail the UK entity classification approach with that of the US, the Netherlands and France. Appendices consider the unusual UK capital gains tax treatment of partnerships, as well as the special transparency rules which can apply where a partnership is party to loans or derivative contracts, or owns intangible assets. Questions of entity classification and tax transparency are of fundamental importance in any mature tax system and especially in a globalised economy. This book unlocks those questions for both academics and practitioners.
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 : Peter H. Blessing,Ansgar A. Simon Publisher : Kluwer Law International B.V. Page : 7048 pages File Size : 51,9 Mb Release : 2020-03-10 Category : Law ISBN : 9789041190734
Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings, 5th Edition by Peter H. Blessing,Ansgar A. Simon Pdf
Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings Fifth Edition Edited by Peter H. Blessing and Ansgar A. Simon About the editors: Peter H. Blessing is Associate Chief Counsel, International, at the Office of Chief Counsel of the Internal Revenue Service. Before his appointment in April 2019, he was the head of cross-border corporate transactions in KPMG’s Washington National Tax group. He is a member of Washington National Tax practice of KPMG LLP. His practice involves transactional, advisory and controversy matters, generally in a cross-border context. Peter obtained his LL.M. Taxation from New York University School of Law and has also earned degrees from Princeton University and Columbia Law School. Ansgar A. Simon heads the transactional tax practice of Covington & Burling LLP in New York. His broad-based transactional tax practice covers mergers and acquisitions, corporate restructuring transactions, divestitures, spin-offs, and joint ventures, as well as the financing of such transactions, generally in a cross-border context. Ansgar received his degree in law from Stanford Law School and a PhD in philosophy from the University of California, Los Angeles. About the book: Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings is a practical overview of key tax aspects of international transactions that have general applications, followed by twenty detailed country profiles. Transactional tax planning always is of critical importance to sound deal making. In the international arena, cross-border mergers and acquisitions continue to proliferate as companies seek to maximize global market opportunities. Whether the transaction be strategic or opportunistic, transformational or conventional expansion, third party or internal value-enhancing restructuring, it is crucial for management and counsel to develop a working knowledge of the salient features of the relevant tax law in a broad range of global jurisdictions. This book, now in its fifth edition, distils knowledge of the tax aspects involved in such transactions across international borders. What’s in this book: This book considers each jurisdiction’s handling of areas of concern in international tax planning such as: – entity classification; – structuring taxable transactions; – structuring tax-free transactions (both in domestic and cross-border transactions); – loss planning; – IP planning; – compensation arrangements; – acquisition financing; – joint venture planning; – value added tax issues; and – tax treaty usage. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations. How this will help you: This user-friendly work assists in planning and evaluating strategies for transactions, both nationally and internationally, in single and multiple jurisdictions, as well as in implementing them. This book further allows an easy comparison of key tax aspects in major jurisdictions, thereby providing not only an easy understanding of the key structuring points in context but also critical issue-spotting as well as highlighting potential value-enhancing strategies. Addressing an important information gap in an area of widespread commercial concern, this resource helps international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals to confidently approach challenging situations in both national and international regime. Editors: Peter H. Blessing and Ansgar A. Simon
Taxation (International and Other Provisions) Act 2010 by Great Britain Pdf
These notes refer to the Taxation (International and Other Provisions) Act 2010 (c. 8) (ISBN 9780105408109) which received Royal assent on 18th March 2010
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 Company Reorganisations by Pete Miller,George Hardy,Fehzaan Ismail Pdf
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)
