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Author : David Southern
Publisher : Unknown
Page : 497 pages
File Size : 41,5 Mb
Release : 2001
Category : Bankruptcy
ISBN : OCLC:50523087
Author : David Southern
Publisher : Unknown
Page : 128 pages
File Size : 52,5 Mb
Release : 2001-12-30
Category : Electronic
ISBN : 0754512193
This title focuses on the practical implications of the provisions on corporate debt, financial instruments and foreign exchange gains and losses. It covers the interaction between the taxes, the accounting framework, corporate transactions and planning issues. It is a comprehensive and practical guide to the corporate and government debt rules, to the tax and accounting treatment of all instruments used in providing corporate finance, and the treatment of foreign exchange gains and losses arising from such financial transactions. Worked examples throughout illustrate complex points, and it is fully cross-referenced to the legislation and Inland Revenue pronouncements. Changes in practice and legislation up to and including the Finance Act 2001 are included.
Author : David Southern
Publisher : Unknown
Page : 536 pages
File Size : 43,5 Mb
Release : 2002
Category : Contracts
ISBN : 0754517888
A new regime for monetary transactions was heralded by the three separate tax codes introduced from 1993 to 1996 for foreign exchange, financial instruments and loan relationships. Now the proposals for the Finance Act 2002 radically consolidates, extends and recasts the new rules and new anti-avoidance provisions have already taken effect from 26 July 2001.
Author : Julian Ghosh,Ian Johnson,Paul Miller
Publisher : Unknown
Page : 800 pages
File Size : 40,8 Mb
Release : 2009-04-14
Category : Electronic
ISBN : 1405747161
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 : John Abrahamson
Publisher : Tolley
Page : 432 pages
File Size : 50,9 Mb
Release : 2014-08-01
Category : Corporations
ISBN : 0754551849
This book introduces and discusses international tax issues relating to corporate finance, group treasury, and banking operations. The book is intended to benefit accountants, lawyers, economists, financial managers and government officials by explaining practical corporate finance international tax issues. These issues include: examples of country tax regimes; corporate finance including issuing shares; debt instruments; bank loans; investment banking activities; and alternative finance such as crowdfunding; microfinance and alternative energy funding; and international tax issues relating to interest and dividend flows; capital gains; and foreign tax credits. The book reviews related topics, including: mergers and acquisitions funding; asset and project finance; securitisation; derivatives; hybrid securities and entities; Islamic financing; bank capital structures; group treasury companies; debt restructuring; and transfer pricing issues. The book is based on Corporate Finance and International Taxation courses presented by the author in London, Paris, Zurich, Lugano, Rio de Janeiro, Mexico City, Hong Kong and Singapore.
Author : John Snape
Publisher : Bloomsbury Publishing
Page : 203 pages
File Size : 43,8 Mb
Release : 2011-12-09
Category : Law
ISBN : 9781847318718
Excellent technical writing on corporation tax abounds, but it tends to be inaccessible to public lawyers, political theorists and political economists. Although recent years have seen not only an explosion in public law scholarship but also a reawakening of interest in interpretative political theory and political economy, the potential of these perspectives to illuminate the corporation tax debate has remained unexplored. In this important work, John Snape seeks to reconcile these disparate strands of scholarship and to contribute to a new way of understanding and conceptualising the reform of the law relating to corporate taxation. Drawing on important developments in public law scholarship, the study combines elements of political theory and political economy. It advances a new interpretation of corporation tax law as an instrument of rule, through the maximisation of a nation's economic potential. Snape shows how corporate taxation belongs at the centre of any discussion of economic globalisation, not only because of the potential of national tax systems to influence inward investment decisions but also because of the potential of those decisions to shape the public interest that those tax systems might embody. Following public law and politics models, the book looks afresh at the impact of Britain's political institutions, of the processes of its representative government and of the theory that moulds and orders the values that the corporation tax code contains. This is a timely exploration of cutting-edge issues of public policy.
Author : Oktavia Weidmann
Publisher : Kluwer Law International B.V.
Page : 439 pages
File Size : 51,6 Mb
Release : 2015-07-16
Category : Law
ISBN : 9789041159830
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 : Arthur James Wells
Publisher : Unknown
Page : 2248 pages
File Size : 45,7 Mb
Release : 2003
Category : Bibliography, National
ISBN : UOM:39015079755925
Author : Malcolm J. Finney
Publisher : Unknown
Page : 0 pages
File Size : 40,5 Mb
Release : 1991
Category : Corporations
ISBN : OCLC:681143030
Author : John Abrahamson
Publisher : Tolley
Page : 410 pages
File Size : 54,6 Mb
Release : 2021-07-19
Category : Electronic
ISBN : 0754558118
Why should you buy Tolley's International Taxation of Upstream Oil and Gas Third editionThis title sets out the significant international tax issues for upstream oil and gas operations, and with an emphasis on tax risk management and related tax planning. Readers will develop skills in identifying tax exposures and opportunities, managing tax negotiations, and applying tax planning solutions.The book is intended to benefit accountants, lawyers, economists, financial managers and government officials, and is the first choice for new starters in upstream oil and gas taxation.The book serves as a great introduction to international tax issues relating to upstream oil and gas, enabling the reader to analyse and understand new situations and circumstances.This third edition explains recent key developments, including the changes in United States upstream oil and gas taxation, the implementation of the OECD Base Erosion and Profit Shifting (BEPS) measures, and the application of the 2017 OECD Transfer Pricing Guidelines, together with related practical case study examples.
Author : Louise Gullifer,Jennifer Payne
Publisher : Bloomsbury Publishing
Page : 910 pages
File Size : 41,9 Mb
Release : 2015-10-22
Category : Law
ISBN : 9781782259596
The second edition of this acclaimed book continues to provide a discussion of key theoretical and policy issues in corporate finance law. Fully updated, it reflects developments in the law and the markets in the continuing aftermath of the Global Financial Crisis. One of its distinctive features is that it gives equal coverage to both the equity and debt sides of corporate finance law, and seeks, where possible, to compare the two. This book covers a broad range of topics regarding the debt and equity-raising choices of companies of all sizes, from SMEs to the largest publicly traded enterprises, and the mechanisms by which those providing capital are protected. Each chapter analyses the present law critically so as to enable the reader to understand the difficulties, risks and tensions in this area of law, and the attempts made by the legislature and the courts, as well as the parties involved, to deal with them. This book will be of interest to practitioners, academics and students engaged in the practice and study of corporate finance law.
Author : International Bureau of Fiscal Documentation
Publisher : Unknown
Page : 652 pages
File Size : 48,6 Mb
Release : 1999
Category : Finance
ISBN : STANFORD:36105113373976
Author : John Abrahamson
Publisher : Kluwer Law International B.V.
Page : 448 pages
File Size : 48,8 Mb
Release : 2020-02-20
Category : Law
ISBN : 9789403510958
Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Author : Anonim
Publisher : Unknown
Page : 514 pages
File Size : 42,8 Mb
Release : 2004
Category : Taxation
ISBN : IND:30000093074452
Author : Anonim
Publisher : Unknown
Page : 956 pages
File Size : 53,6 Mb
Release : 2003
Category : Law
ISBN : STANFORD:36105063856194
