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Author : Frank J. Fabozzi, CFA Publisher : John Wiley & Sons Page : 320 pages File Size : 53,5 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.
Taxation of Corporate Debt and Derivatives by Julian Ghosh,Ian Johnson,Paul Miller Pdf
Offering invaluable tax planning help for the tax specialist, 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 : Mark J. P. Anson Publisher : John Wiley & Sons Page : 228 pages File Size : 48,7 Mb Release : 1999-09-15 Category : Business & Economics ISBN : 1883249619
Credit derivatives have become one of the fastest-growing areas of interest in global derivatives and risk management. In Credit Derivatives, Mark Anson skillfully examines this unique investment tool that is now being used to manage credit risk in banking and capital markets around the world. Credit Derivatives discusses everything from the basics of why credit risk is important to accounting and tax implications of credit derivatives. This essential guidebook to credit derivatives covers key topics including, credit swaps, credit forwards, credit linked notes, and credit derivative pricing models. Anson also touches on other important credit derivative issues by discussing the implications of credit risk management as well as credit derivative regulation.
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 : Mark J. P. Anson Publisher : John Wiley & Sons Page : 202 pages File Size : 45,7 Mb Release : 1999-11-09 Category : Business & Economics ISBN : 1883249694
Accounting and Tax Rules for Derivatives by Mark J. P. Anson Pdf
Derivatives and credit derivatives have emerged as significant areas of interest in portfolio planning and risk management. In this book, Mark Anson examines the accounting and taxation implications of these instruments, including the new accounting rules for derivative instruments promulgated by the financial Accounting Standards in the United States, the Accounting Standards Board in Great Britain, and the International Accounting Standards Committee. Regulatory requirements for disclosing derivatives and tax considerations for derivative instruments are discussed (including TRA-97.) Additionally, the book reviews the regulatory accounting deadlines introduced by the Securities and Exchange Commission and the Commodity Futures Trading Commission.
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 : Mark J. P. Anson Publisher : John Wiley & Sons Incorporated Page : 188 pages File Size : 48,9 Mb Release : 2004-11 Category : Business & Economics ISBN : 0471732745
Accounting and Tax Rules for Derivatives by Mark J. P. Anson Pdf
Derivatives and credit derivatives have emerged as significant areas of interest in portfolio planning and risk management.In this book, Mark Anson examines the accounting and taxation implications of these instruments, including the new accounting rules for derivative instruments promulgated by the financial Accounting Standards in the United States, the Accounting Standards Board in Great Britain, and the International Accounting Standards Committee. Regulatory requirements for disclosing derivatives and tax considerations for derivative instruments are discussed (including TRA-97.) Additionally, the book reviews the regulatory accounting deadlines introduced by the Securities and Exchange Commission and the Commodity Futures Trading Commission.
Shadow banking – a system of credit creation outside traditional banks – lies at the very heart of the global economy. It accounts for over half of global banking assets, and represents a third of the global financial system. Although the term ‘shadow banking’ only entered public discourse in 2007, the importance and scope of this system is now widely recognised by the international policy-makers. There is, however, much less consensus on the origins of the shadow banking system, what role it plays in global political economy and the optimal approach to regulating this complex segment of finance. This volume addresses these questions. Shadow Banking is the first study to bring together the insights from financial regulators, practitioners and academics from across the social sciences. The first part traces the evolution and ongoing confusion about the meaning of ‘shadow banking’. The second section draws major lessons about shadow banking as posed by the financial crisis of 2007–09, providing comparative analyses in the US and Europe, and attempts to establish why shadow banking has emerged and matured to the level of a de facto parallel financial system. Finally, the third part goes beyond current regulatory concerns about shadow banking and explains why it is ‘here to stay’. This volume is of great importance to political economy, banking and international political economy.
Apractitioner's Guide to Tax Planning with Trusts by Members Of New Square Chambers Pdf
A Practitioner's Guide to Tax Planning with Trusts offers the most up-to-date tax-efficient planning guidance using trusts. It looks at some of the key areas in this field such as succession planning, the use of derivatives and the use of trusts in charitable giving (which has significant taxation implications).
Combating Fiscal Fraud and Empowering Regulators by Brigitte Unger,Lucia Rossel,Joras Ferwerda Pdf
This is an open access title available under the terms of a CC BY-NC-ND 4.0 International licence. It is free to read at Oxford Scholarship Online and offered as a free PDF download from OUP and selected open access locations. Combating Fiscal Fraud and Empowering Regulators analyzes the impact of new international tax regulations on the scope and scale of tax evasion, tax avoidance, and money laundering. These are analyzed through an ecosystem framework in which, similar to a natural ecosystem, new tax regulations appear as heavy shocks to the tax ecosystem, to which the 'species' such as countries, corporations, and tax experts will react by looking for new loopholes and niches of survival. By analyzing the impact of tax reforms from different perspectives--a legal, political science, accounting, and economic one--one may derive an assessment of the reforms and policy recommendations for an improved international tax system. The ultimate goal is to combat fiscal fraud and empower regulators, in that line, this volume is intended for a broad audience that seeks to know more about the latest state of the art in the realm of taxation from a multidisciplinary perspective. The money involved amounts to billions in unpaid taxes that could be better used for stopping hunger, guaranteeing education, and safeguarding biodiversity, hence making this world a better one. Regulators can see this book as a guiding light of what has happened in the past forty years, and how the world has and will continue to change as a result of it. Combating Fiscal Fraud and Empowering Regulators is also a warning about new emerging tax loopholes, such as freeports or golden passports and visas, where residency can be bought in tax havens, even within the European Union. The main message is that inequality can and has to be reduced substantially and that this can be achieved through a well-working international tax system that eliminates secrecy, opaqueness, and tax havens.
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.
Shares, Derivatives and Taxation by Tony Compton Pdf
For an investor, the cost of acquiring a parcel of shares is a capital cost and the shares become an asset. For a share trader, this cost is the cost of acquiring trading stock and is therefore an expense incurred in producing assessable income. The difference in the tax treatment between assets and stock ?and between investors and traders ?is enormous. What are these differences? When does an investor become a trader? These and many other questions are answered in this new book.Tony Compton uses his many years of experience as an accountant to guide the reader through a wide range of tax issues, from setting up a company for trading to timing the sale of shares, and claiming expenses. He pays particular attention to the legal differences between being a trader and investor, and the significant effect this will have on available tax deductions. He also discusses dividends, negative gearing, capital gains tax, record-keeping, futures, managed funds and tax planning. The author provides a wide range of examples to demonstrate the effect of different approaches. Checklists are also provided for traders and investors to ensure they are claiming their deductions in full.
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.
United States. Congress. Senate. Committee on Finance,United States. Congress. House. Committee on Ways and Means
Author : United States. Congress. Senate. Committee on Finance,United States. Congress. House. Committee on Ways and Means Publisher : Unknown Page : 548 pages File Size : 46,9 Mb Release : 2011 Category : Financial instruments ISBN : MINN:31951D03509293I
Tax Reform and the Tax Treatment of Financial Products by United States. Congress. Senate. Committee on Finance,United States. Congress. House. Committee on Ways and Means Pdf
