Using Treaties And Holding Companies For Latin American Tax Planning
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Using Treaties and Holding Companies for Latin American Tax Planning by Amanda D. Johnson Pdf
Collection of articles providing an insight in the current status of tax treaties in Latin American and Caribbean countries, and dealing with holding companies and technical assistance, royalty and service payments.
Using Treaties and Holding Companies for Latin American Tax Planning by Katherine Dimancescu Pdf
Revised to help businesspeople navigate treaty planning in the dynamic Latin American marketplace, this reference provides details on tax consolidation regimes and holding companies as investment vehicles, and insight into technical assistance as well as royalty and service payments.
Tax Planning with Holding Companies - Repatriation of US Profits from Europe by Rolf Eicke Pdf
The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
Tax Planning for U.S. MNCs with EU Holding Companies by Pia Dorfmueller Pdf
Tax planning for U.S. companies doing business in the EU. Analyses the design of tax conversion and deferral structures that are advantageous to U.S. multinationals to reach their goals: minimizing liability, maximizing credits, deducting expenses, and utilizing losses; using tools such as routing of income and classification of entities; and overcoming barriers like the CFC provisions of the U.S. tax law. Examines U.S. federal corporate law and analyses European company taxation, with specific tax planning techniques for Germany, France, the Netherlands, Belgium, Austria, Denmark, Ireland, Spain, Luxembourg, and Switzerland.
Special Report on Securitization in Asia and the Pacific Rim: 2005 by Judy S. Kuan Pdf
SPECIAL REPORT ON SECURITIZATION IN ASIA AND THE PACIFIC RIM: 2005 is a one-of-a-kind report from the editors of the International Securitization & Finance newsletter that will help you gain a deeper understanding of how others have found the greatest successes in these markets. With in-depth coverage of the more-developed markets as well as insight into the newer entries, the report provides the most comprehensive study available of the region's diverse securitization marketplace. Over 230 pages of articles, research, and statistics presented by renowned editors and successful practitioners provide you with the tools you need to develop successful ABS and MBS deals in this region.
Special Report on Securitization in Europe: 2005 by Amanda D. Johnson Pdf
Improve your firm's European structured finance operations with this in-depth analysis of the most popular structured finance instruments in use today, including collateralized debt, mortgage-backed securities, as well as whole-business and synthetic securitizations. You'll find how others have found the greatest successes in the European market, which is equivalent in maturity and scope to those of North America. You'll get specific practical insight you can use right away, like how to take advantage of regional legal structures that make it possible to develop structures and add features not possible in other regions.
Offshore Business Sourcing Special Report on Law & Strategy by Ian Springsteel,Judy S. Kuan Pdf
Now, there's a unique resource developed specifically for senior managers and legal professionals tasked with ensuring their offshore sourcing contracts result in increased bottom lines ... not increased legal battles. The OFFSHORE BUSINESS SOURCING SPECIAL REPORT ON LAW & STRATEGY will help you navigate the many legal and strategic hurdles inherent to the offshoring process. You'll stay ahead of changing legislation, uncover effective tax structuring options, and learn strategies to overcome intellectual property challenges.
Russia Tax, Law and Business Briefing: 2006 by Amanda D. Johnson Pdf
The restructuring of Russia's legal and regulatory frameworks in the past decade have created new conditions for investment and business ventures, offering both new opportunities and challenges to the prospective investor. Russia Tax, Law & Business Briefing: 2006 provides guidance on tax and legal issues investors should consider when evaluating a possible company acquisition, starting a business or entering into a joint venture or strategic alliance in Russia. Coverage includes: *An analysis of Russia's overall economy in the context of its strong oil and gas sectors, including the macroeconomic effects of changes in oil prices; *The restructuring and resulting creditworthiness of Russian banks five years after the 1998-1999 financial crisis; *A discussion of the performance of the Russian ruble against the dollar and the euro, and the resulting impact on Russia's trade balance and inflation rate; *Drugstore chain 36.6's successful launching of the first IPO in Russia by a retail company, and the second domestic IPO in the country's history; and *The prospects for project financing in Russia's fossil fuels sector, as well as other restructuring and privatization developments in the energy market. As with all WorldTrade publications, Russia Tax, Law & Business Briefing: 2004 is written by leading practitioners in the region. Top law firms and ratings companies offer commentary and analysis concerning the current status of the banking, energy, intellectual property, labor, trade, and real estate sectors.
Author : Peter H. Blessing,Ansgar A. Simon Publisher : Kluwer Law International B.V. Page : 7048 pages File Size : 54,7 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
Author : Ansgar A. Simon Publisher : Kluwer Law International B.V. Page : 2424 pages File Size : 47,8 Mb Release : 2023-08-31 Category : Law ISBN : 9789403547138
Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings by Ansgar A. Simon Pdf
This classic handbook has once again been updated from cover to cover, assuring its secure place as the preeminent tax practice guide for the conduct of international business transactions. The user-friendly structure has been maintained—first, a hands-on overview of certain key tax aspects of international transactions that have general application (including a chapter on special issues for transactions touching the European Union), followed by detailed country profiles that offer solutions designed to maximize effective tax planning and satisfy compliance obligations in twenty key global trading jurisdictions. The expert country-by-country contributors explain each jurisdiction’s approach to the critical areas of concern in transactional tax planning, addressing among other issues: entity classification; taxable transactions; tax-free transactions (both domestic and cross-border); loss and other tax attribute planning; intellectual property transactions; compensation arrangements; acquisition financing; joint ventures; transfer pricing; VAT; and tax treaty usage. Because it is crucial for management and counsel to develop a working knowledge of the salient aspects of the relevant law in a broad range of global jurisdictions, the work is of immeasurable value in assessing, strategizing, and implementing international transactions while also allowing quick jurisdictional comparison of key tax aspects. Addressing an important information gap in an area of widespread commercial concern, this incomparable resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals.
Global Transfer Pricing Solutions by Judy S. Kuan Pdf
GLOBAL TRANSFER PRICING SOLUTIONS: 2004 covers the major transfer pricing regimes around the world with in-depth discussion and analysis of such topics as proactive transfer pricing management of post-merger integrations, e-commerce and intellectual property. This report was prepared by members of major law and accounting firms and senior international transfer pricing professionals at the largest multinationals. It covers a wide range of tools and techniques relevant to transfer pricing in Asia, Europe, Latin America, and North America.
Belgium in International Tax Planning by Patrick A. A. Vanhaute Pdf
This book focuses on commercial and company law and corporate income tax. It provides a systematic and comprehensive overview of the current tax planning opportunities that exist in Belgium. After some essential legal knowledge of Belgium, the chapters consider the Belgian tax regime, special features of the Belgian tax system, specific anti-avoidance provisions and international tax planning, tax incentives, special tax regimes, and tax planning opportunities (including the tax treaties with Hong Kong, the USA and the UAE).
