The Role Of Tax Law In Mergers And Acquisitions

Author : Chunyang Zhang
Publisher : Kluwer Law International B.V.
Page : 207 pages
File Size : 45,7 Mb
Release : 2022-08-08
Category : Law
ISBN : 9789403537627

Get Book

The Role of Tax Law in Mergers and Acquisitions by Chunyang Zhang Pdf

Series on International Taxation, Volume 82 The economic value of China’s mergers and acquisitions (M&A) market is exceeded only by that of the United States. However, China’s rapid and somewhat chaotic economic transformation has made the task of taxing M&A transactions in a consistent and prudent manner difficult, leading to a patchwork of fragmented rules that are hard to grasp not only for taxpayers but even for tax professionals and tax officials. Responding to this complex situation, this groundbreaking book explores in detail how income derived from M&A transactions is taxed in China. Using empirical studies in order to provide a first-hand understanding of the context in which the tax law operates, the book critically examines China’s income tax regime for M&A and, based upon this examination, sets out reform proposals. In six informative chapters of great practical relevance, the author thoroughly describes and explains the intersection of such aspects as the following: M&A transactions in the eyes of tax law; disparities between ordinary and special tax treatment; eligibility for special tax treatment; applying taxation principles such as neutrality and equity; continuity of interest doctrine; stock acquisition versus asset acquisition; and adjustment to tax basis. In addition to its empirical research, the analysis makes use of an examination of the rules and theories on taxing M&A in other jurisdictions such as Australia and the United States as part of its proposed blueprint for improving China’s M&A taxation. Drawing on commonly recognized taxation principles, this book definitively sets up the normative criteria for evaluating the income taxation of M&A and reveals the fundamental problems encountered by China’s current regime. Its comprehensive analysis of the Chinese income tax rules for M&A and detailed disclosure of how they are both divergent from and convergent with that of some other major economies will prove of immeasurable value to in-house counsel for multinational corporations, business enterprises with interests in China, taxation consultants, taxation academics, and taxation authorities worldwide.

Author : Peter H. Blessing,Ansgar A. Simon
Publisher : Kluwer Law International B.V.
Page : 7048 pages
File Size : 54,5 Mb
Release : 2020-03-10
Category : Law
ISBN : 9789041190734

Get Book

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

Author : PricewaterhouseCoopers LLP.
Publisher : Unknown
Page : 584 pages
File Size : 55,5 Mb
Release : 2006
Category : Consolidation and merger of corporations
ISBN : UCSD:31822035427822

Get Book

Mergers and Acquisitions by PricewaterhouseCoopers LLP. Pdf

This book describes the current and anticipated (over the next twelve months) environment for mergers and acquisitions in forty-two specific countries or territories. It provides a general description of the various options available when structuring M & A transactions and introduces relevant tax system(s) and forms (entities) of doing business. .

Author : Samuel Coleman Thompson (Jr.)
Publisher : Unknown
Page : 0 pages
File Size : 45,9 Mb
Release : 2016
Category : Business enterprises
ISBN : 1611631750

Get Book

Corporate Taxation Through the Lens of Mergers & Acquisitions by Samuel Coleman Thompson (Jr.) Pdf

To view or download the 2018 Supplement to this book, click here. This book approaches corporate taxation through the lens of the M&A provisions of the Internal Revenue Code. To ensure that the reader has the appropriate background to explore concepts, Chapter 2 provides an introduction to basic corporate tax principles. Because of the globalization of business activity, this book introduces many of the issues under the Code affecting both inbound and outbound cross-border transactions. The book also looks at various proposals to reform corporate taxation.

Author : United States. Congress. House. Committee on Ways and Means
Publisher : Unknown
Page : 964 pages
File Size : 43,6 Mb
Release : 1989
Category : Consolidation and merger of corporations
ISBN : PURD:32754078652868

Get Book

Tax Policy Aspects of Mergers and Acquisitions by United States. Congress. House. Committee on Ways and Means Pdf

Author : Philip Cooke,Jan M. van der Beek
Publisher : Springer
Page : 160 pages
File Size : 43,5 Mb
Release : 1983-10-31
Category : Business & Economics
ISBN : UOM:35112101890509

Get Book

Tax Aspects of Acquisitions and Mergers by Philip Cooke,Jan M. van der Beek Pdf

Compilation of country studies by various contributors dealing in a comparative way with the taxation and other related aspects of acquisitions and mergers, both at the domestic level and cross-frontier. Includes general report and country reports on Belgium, Canada, Denmark, France, Germany, Ireland, Italy, Netherlands, Spain, United Kingdom and United States of America.

Author : PriceWaterhouseCoopers LLP
Publisher : John Wiley & Sons
Page : 577 pages
File Size : 43,9 Mb
Release : 2006-07-13
Category : Business & Economics
ISBN : 9780471998075

Get Book

Mergers and Acquisitions by PriceWaterhouseCoopers LLP Pdf

How you handle global tax issues can make or break a deal. Gain a better understanding of these issues with guidance from PricewaterhouseCoopers' Mergers and Acquisitions: A Global Tax Guide When a business engages in a multinational merger or acquisition, dealing with a diverse set of transaction-related tax rules is one of the major challenges to successful implementation. PricewaterhouseCoopers' Mergers and Acquisitions: A Global Tax Guide helps you navigate the complexities unique to these international deals. This invaluable guide focuses on the global tax aspects of mergers and acquisitions to provide you with the information you need to move the deal forward-under a variety of circumstances and in numerous markets. Presenting individual chapters for each of thirty-one countries, this essential handbook provides quick access to the tax information you need, and, as much as possible, reduces the effort required to compare the rules that apply in one jurisdiction with the rules that apply in others. Each country-specific chapter includes an overview of the general approaches to mergers and acquisitions taxation issues as well as detailed information about how the tax authorities in each country apply the rules to various aspects of a transaction. PricewaterhouseCoopers' Mergers and Acquisitions: A Global Tax Guide offers tax planners a foundation of information that they need when involved in international mergers and acquisitions. It also covers many of the finer points of the broader tax issues that arise during planning and negotiation. Many will find this valuable reference to be an indispensable desktop tool in their effort to gain a deeper understanding of the global tax environment.

Author : Peter H. Blessing
Publisher : Unknown
Page : 0 pages
File Size : 50,9 Mb
Release : 2015
Category : Consolidation and merger of corporations
ISBN : 9041161228

Get Book

Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings by Peter H. Blessing Pdf

This user-friendly resource is comprised of two complementary parts: first, a practical overview of certain key tax aspects of international transactions that have general application, followed by twenty-one detailed country profiles, pinpointing each jurisdiction's handling of such areas of concern as entity classification, taxable transactions, tax-free transactions (both domestically and cross-border), loss planning, IP planning, compensation arrangements, acquisition financing, JV planning, VAT issues, tax treaty usage, and much more. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations. The work will assist in planning and evaluating strategies for transactions in single and multiple jurisdictions, as well as in implementing them. It further will allow an easy comparison of key tax aspects in major jurisdictions. Addressing an important information gap in an area of widespread commercial concern, this resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals. Contributing authors: Marti Adroer, Soo-Jeong Ahn, Javier Asensio, Daniel Bader, Xavier Berre, Peter H. Blessing, Jose Carlos Silva, Agn�s Charpenet, David Caupers, Stephan Eilers, Shefali Goradia, Gabriel Gotlib, Daniel Gustafsson, Richard Hendriks, Werner Heyvaert, Soraya M. Jamal, John Jangwoon Kwak, Josh Jones, Sophie Jouniaux, Janne Juusela, Michael Khayat, Kirsten Kjellander, Robert Kopstein, Daniel Lehmann, Sanna Lindqvist, Margriet E. Lukkien, Ricardo Luiz Becker, Victor Matchekhin, Michael McGowan, Patrick Mears, Riccardo Michelutti, Takeo Mizutani, Stephen Nelson, Janette Pantry, Peter Reinarz, Eric N. Roose, M�nica Sada Garibay, Martin Schiessl, Michael H. Shikuma, Ansgar A. Simon, Jin Soo Soh, James Smith, Raoul Stocker, Andrew Stuart, Peng Tao, Peter Utterstr�m, Adalberto Valadez, Maarten J.M. van der Weijden, Richard Vann, Chris Van Loan, Fernando M. Vaquero, Fl�vio Veitzman, Sonia Velasco and Sabrina Wong. "

Author : Alexandra Reed Lajoux,H. Peter Nesvold
Publisher : McGraw Hill Professional
Page : 402 pages
File Size : 45,6 Mb
Release : 2003-10-22
Category : Business & Economics
ISBN : 9780071435932

Get Book

The Art of M&A Structuring by Alexandra Reed Lajoux,H. Peter Nesvold Pdf

Real-world advice for determining the most advantageous structure in a merger, acquisition, or buyout The actual structuring of a merger or acquisition is key to the success of the entire procedure. The Art of M&A Structuring explores ways to approach a deal as an investment and satisfy the often conflicting financial and operational goals of all parties, from buyers and sellers to investors and lenders. Written in the trademark Q&A style that made The Art of M&A a landmark business bestseller, this book is filled with real-world examples and cases. Decision makers in any organization will quickly find the M&A information and insights they need, including: Up-to-date GAAP and tax considerations Advantages and disadvantages of spin-offs and spin-outs Special considerations for off-balance-sheet transactions

Author : United States. Congress. Senate. Committee on Finance
Publisher : Unknown
Page : 364 pages
File Size : 48,5 Mb
Release : 1982
Category : Consolidation and merger of corporations
ISBN : UOM:39015082325914

Get Book

Tax Treatment of Corporate Mergers and Acquisitions, and of Certain Distributions of Appreciated Property, and Job Training Credit Proposal by United States. Congress. Senate. Committee on Finance Pdf

Author : Vivian Poon,Kelli Patel
Publisher : Kluwer Law International B.V.
Page : 165 pages
File Size : 51,5 Mb
Release : 2022-05-20
Category : Law
ISBN : 9789403547329

Get Book

Corporate Acquisitions and Mergers in Canada by Vivian Poon,Kelli Patel Pdf

Derived from Kluwer’s multi-volume Corporate Acquisitions and Mergers, the largest and most detailed database of M&A know-how available anywhere in the world, this work by a highly experienced partner in the leading international law firm Dentons Canada LLP provides a concise, practical analysis of current law and practice relating to mergers and acquisitions of public and private companies in Argentina. The book offers a clear explanation of each step in the acquisition process from the perspectives of both the purchaser and the seller. Key areas covered include: structuring the transaction; due diligence; contractual protection; consideration; and the impact of applicable company, competition, tax, intellectual property, environmental and data protection law on the acquisition process. Corporate Acquisitions and Mergers is an invaluable guide for both legal practitioners and business executives seeking a comprehensive yet practical analysis of mergers and acquisitions in Canada. Equivalent analyses of M&A law and practice in some 50 other jurisdictions, all contributed by leading law firms, are accessible on-line at www.kluwerlawonline.com under Corporate Acquisitions and Mergers.

Author : Samuel C. Thompson
Publisher : Unknown
Page : 696 pages
File Size : 47,5 Mb
Release : 2007
Category : Business & Economics
ISBN : STANFORD:36105064179836

Get Book

U.S. International Tax Planning and Policy by Samuel C. Thompson Pdf

To access the 2010 Supplemental Materials, click here. This book addresses the provisions of the Internal Revenue Code that govern the U.S. operations of foreign persons (i.e., inbound transactions) and the foreign operations of U.S. persons (i.e., outbound transactions). Part I provides a general introduction and introduces the impact of tax treaties; Part II focuses on the taxation of inbound transactions and addresses such issues as the U.S. taxation of a branch or U.S. subsidiary owned by a foreign corporation. Part III considers outbound transactions and deals with the U.S. taxation of foreign corporations controlled by U.S. persons. This part also addresses the rules regarding transfer pricing between commonly controlled entities, such as a U.S. parent corporation and its foreign subsidiary. Part IV focuses on cross-border mergers and acquisitions. Particular attention is given to the role of Section 367 on cross border reorganizations. The last sections of most chapters briefly discuss the manner in which South Africa, which has recently reformed its international tax system, addresses the issues presented in the chapter. From a tax planning standpoint, the U.S. tax advisor should have a basic understanding of the interface between the U.S. and foreign tax system involved in the transaction, and these discussions illustrate the interface between two sophisticated systems: the U.S. and South Africa.

Author : Anonim
Publisher : Unknown
Page : 232 pages
File Size : 42,9 Mb
Release : 1984
Category : Consolidation and merger of corporations
ISBN : PURD:32754076289945

Get Book

Federal Income Tax Considerations in Oil and Gas Company Mergers and Acquisitions by Anonim Pdf

Author : Insight Information Inc
Publisher : Unknown
Page : 730 pages
File Size : 51,7 Mb
Release : 1998
Category : Business & Economics
ISBN : STANFORD:36105061971185

Get Book

Global Mergers and Acquisitions by Insight Information Inc Pdf

Author : Joseph B. Darby
Publisher : CCH
Page : 542 pages
File Size : 47,6 Mb
Release : 2006
Category : Business & Economics
ISBN : 0808014706

Get Book

Practical Guide to Mergers, Acquisitions and Business Sales by Joseph B. Darby Pdf

"Buying and selling a business is a challenging process. It involves rituals and interactions that are sometimes eerily similar to the courtship dynamic between a human couple. While many business courtships end in an economic marriage, plenty of others fail and for a variety of reasons. Many unsuccessful business negotiations could have made sense, but ultimately floundered, because negotiations went badly awry at some crucial point. CCH's brand-new Practical Guide to Mergers, Acquisitions and Business Sales by seasoned business transaction attorney and author, Joseph B. Darby III, J.D., not only explains the tax aspects of buying and selling a business, but examines the special art of closing major business transactions successfully through an understanding of the tax consequences of the deal. ; There also are two other parties with a major economic stake in a business merger, acquisition or sale: the federal government and (usually at least one) state government. The role of a tax adviser on an business acquisition transaction is to make everyone aware that there are two "silent partners" in the room at all times and that the Buyer and Seller have a common interest in cutting the silent partners out of the deal or reducing their take. The purpose and mission of Practical Guide to Mergers, Acquisitions and Business Sales is to teach practitioners and business stakeholders how to pare the tax costs of transactions to the absolute minimum, within the boundaries of ethical and appropriate tax reporting."--Publisher's website.