Download or read book Hybrid Financial Instruments in International Tax Law written by Jakob Bundgaard and published by Kluwer Law International B.V.. This book was released on 2016-11-15 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity. Focusing on hybrid financial instruments (HFIs) – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – this book analyses their treatment under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered. Advocating for a broader scope of application of HFIs as part of the financing of companies in Europe alongside traditional sources of debt and equity financing, the book addresses such issues and topics as the following: • problems associated with the debt-equity distinction in international tax law; • cross-border tax arbitrage and linking rules; • drivers behind the use and design of HFIs; • tax law impact of perpetual and super maturity debt instruments, profit participating loans, convertible bonds, mandatory convertible bonds, contingent convertibles, preference shares and warrant loans on HFIs; • financial accounting treatment; • administrative guidance; • influence of the TFEU on Member States’ approaches to classification of HFIs; • interpretation of the Parent-Subsidiary Directive by the European Court of Justice; • applicability of the OECD Model Tax Convention; and • implications of the OECD Base Erosion and Profit Shifting (BEPS) project. Throughout this book, the analysis draws upon preparatory works, case law, and legal theory in English, German, and the Scandinavian languages. In conclusion, the author considers tax policy issues, and identifies and outlines possible high-level solutions. Actual or potential users of HFIs will greatly appreciate the clarity and insight offered here into the capacity and tax implications of HFIs. The book not only examines whether existing legislation is sufficient to handle the issues raised by international HFIs, but also provides an in-depth analysis of the interaction between corporate financing and tax law in the light of today’s financial innovation. Corporate executives and their counsel will find it indispensable in the international taxation landscape that is currently coming into view, and academics and policymakers will hugely augment their understanding of a complex and constantly changing area of tax law.
Download or read book Hybrid Financial Instruments Double Non Taxation and Linking Rules written by Félix Daniel Martínez Laguna and published by Kluwer Law International B.V.. This book was released on 2019-06-12 with total page 668 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.
Download or read book The Taxation of Global Trading of Financial Instruments written by OECD and published by OECD Publishing. This book was released on 1998-03-09 with total page 71 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication thoroughly reviews the factual background to global trading, analyses the challenges posed to traditional taxation methods and discusses a range of policy options to tackle the problems.
Download or read book Federal Income Taxation of Banks and Financial Institutions written by Stanley I. Langbein and published by Warren Gorham & Lamont. This book was released on 2001 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Federal Income Taxation of Debt Instruments written by David C. Garlock and published by . This book was released on 1991 with total page 646 pages. Available in PDF, EPUB and Kindle. Book excerpt: Federal Income Taxation of Debt Instruments is the definitive reference for the many complicated issues involved with debt instruments. This comprehensive treatise contains clear interpretations of the basic rules governing original issue discount and imputed interest and detailed coverage of many specialized topics. In addition to complete coverage of the final OID regulations, the book covers virtually every aspect of the taxation of debt instruments and many related areas.
Download or read book Financial Instruments and Institutions written by Stephen G. Ryan and published by John Wiley & Sons. This book was released on 2007-04-10 with total page 616 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is an authoritative guide to the accounting and disclosure rules for financial institutions and instruments. It provides guidance from a “fair value” perspective and demonstrates the simplest and most natural measurement basis for reporting financial instruments, as is relevant for thrifts, mortgage banks, commercial banks, and property-casualty and life insurers.
Download or read book International Taxation of Banking written by John Abrahamson and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 468 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Introduction to the Taxation of Financial Instruments written by Henry D. Shereff and published by . This book was released on 1990 with total page 426 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Accounting for Financial Instruments written by Emanuel Camilleri and published by Routledge. This book was released on 2017-05-12 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Accounting for Financial Instruments is about the accounting and regulatory framework associated with the acquisition and disposal of financial instruments; how to determine their value; how to manage the risk connected with them; and ultimately compile a business valuation report. Specifically, the book covers the following topics, amongst others: Accounting for Investments; Bills of exchange; Management of Financial Risks; Financial Analysis (including the Financial Analysis Report); Valuation of a business (including the Business Valuation Report) and Money laundering. Accounting for Financial Instruments fills a gap in the current literature for a comprehensive text that brings together relevant accounting concepts and valid regulatory framework, and related procedures regarding the management of financial instruments (investments), which are applicable in the modern business world. Understanding financial risk management allows the reader to comprehend the importance of analysing a business concern. This is achieved by presenting an analytical framework to illustrate that an entity’s performance is greatly influenced by its external and internal environments. The analysis of the external environment examines factors that impact an entity’s operational activities, strategic choices, and influence its opportunities and risks. The analysis of the internal environment applies accounting ratio analysis to an entity’s financial statements to examine various elements, including liquidity, profitability, asset utilisation, investment, working capital management and capital structure. The objective of the book is to provide a fundamental knowledge base for those who are interested in managing financial instruments (investments) or studying banking and finance or those who wish to make financial services, particularly banking and finance, their chosen career. Accounting for Financial Instruments is highly applicable to both professional accountants and auditors and students alike.
Download or read book Federal Taxation of Income Estates and Gifts written by Boris I. Bittker and published by Warren Gorham & Lamont. This book was released on 1999 with total page 852 pages. Available in PDF, EPUB and Kindle. Book excerpt: Vol. 3 also issed as rev. 3rd ed. ; rev. 3rd edition of other vols. not planned.
Download or read book Business Taxation and Financial Decisions written by Deborah Schanz and published by Springer Science & Business Media. This book was released on 2010-10-17 with total page 415 pages. Available in PDF, EPUB and Kindle. Book excerpt: Managerial decisions are considerably influenced by taxes: e.g. the choice of location, buying or leasing decisions, or the proper mix of debt and equity in the company's capital structure increasingly demand qualified employees in an economic environment that is becoming more and more complex. Due to the worldwide economic integration and constant changes in tax legislation, companies are faced with new challenges – and the need for information and advice is growing accordingly. This book's goal is to identify and quantify possible tax effects on companies' investment strategies and financing policies. It does not focus on details of tax law, but instead seeks to address students and practitioners focusing on corporate finance, accounting, investment banking and strategy consulting.
Download or read book Taxing Financial Transactions written by Ms.Thornton Matheson and published by International Monetary Fund. This book was released on 2011-03-01 with total page 50 pages. Available in PDF, EPUB and Kindle. Book excerpt: In reaction to the recent financial crisis, increased attention has recently been given to financial transaction taxes (FTTs) as a means of (1) raising revenue for a variety of possible purposes and/or (2) helping to curb financial market excesses. This paper reviews existing theory and evidence on the efficacy of an FTT in fulfilling those tasks, on its potential impact, and on key issues to be faced in designing taxes of this kind.
Download or read book Understanding the Mathematics of Personal Finance written by Lawrence N. Dworsky and published by John Wiley & Sons. This book was released on 2009-09-22 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt: A user-friendly presentation of the essential concepts and tools for calculating real costs and profits in personal finance Understanding the Mathematics of Personal Finance explains how mathematics, a simple calculator, and basic computer spreadsheets can be used to break down and understand even the most complex loan structures. In an easy-to-follow style, the book clearly explains the workings of basic financial calculations, captures the concepts behind loans and interest in a step-by-step manner, and details how these steps can be implemented for practical purposes. Rather than simply providing investment and borrowing strategies, the author successfully equips readers with the skills needed to make accurate and effective decisions in all aspects of personal finance ventures, including mortgages, annuities, life insurance, and credit card debt. The book begins with a primer on mathematics, covering the basics of arithmetic operations and notations, and proceeds to explore the concepts of interest, simple interest, and compound interest. Subsequent chapters illustrate the application of these concepts to common types of personal finance exchanges, including: Loan amortization and savings Mortgages, reverse mortgages, and viatical settlements Prepayment penalties Credit cards The book provides readers with the tools needed to calculate real costs and profits using various financial instruments. Mathematically inclined readers will enjoy the inclusion of mathematical derivations, but these sections are visually distinct from the text and can be skipped without the loss of content or complete understanding of the material. In addition, references to online calculators and instructions for building the calculations involved in a spreadsheet are provided. Furthermore, a related Web site features additional problem sets, the spreadsheet calculators that are referenced and used throughout the book, and links to various other financial calculators. Understanding the Mathematics of Personal Finance is an excellent book for finance courses at the undergraduate level. It is also an essential reference for individuals who are interested in learning how to make effective financial decisions in their everyday lives.
Download or read book State Taxation written by Jerome R. Hellerstein and published by . This book was released on 1998 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation written by Stephen Smith and published by Oxford University Press, USA. This book was released on 2015 with total page 153 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax revenues pay for many public services, including roads, health care, and education. However, it has become a contentious political issue of public debate. In this volume, Stephen Smith explains its history and its main principles; arguing that we'd all benefit from an understanding of the role of taxation in society.
Download or read book Employment Law Review written by Erika C Collins and published by Law Business Research Ltd.. This book was released on 2017-04-07 with total page 1263 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Employment Law Review, edited by Erika C Collins of Proskauer Rose LLP, serves as a tool to help legal practitioners and human resources professionals identify issues that present challenges to their clients and companies. As well as in-depth examinations of employment law in 48 jurisdictions, the book provides further general interest chapters covering the variety of employment-related issues that arise during cross-border merger and acquisition transactions, aiding practitioners and human resources professionals who conduct due diligence and provide other employment-related support in connection with cross-border corporate M&A deals. Other chapters deal with global diversity and inclusion initiatives across the globe, social media and mobile device management policies, and the interplay between religion and employment law. Contributors include: Els de Wind, Van Doorne; Annie Elfassi, Loyens Loeff. "e;Excellent publication, very helpful in my day to day work."e; - Mr Frederic Thoral, Head of HR, BNP Paribas"e;Excellent coverage and detail on each country is brilliant."e; - Mr Raani Costelloe, General manager of Legal and Business Affairs, Sony music Entertainment, Australia"e;An excellent resource for in-house counsel for a company with an international footprint."e; - Mr John R Pendergast, Senior Counsel, BASF Corporation, USA"e;It's invaluable to any lawyer dealing with cross-border and privacy-related employment issues and is a cornerstone to my own legal research"e; - Oran Kiazim, Vice President, Global Privacy, SterlingBackcheck, UK
Download or read book Taxation of Foreign Investment in U S Real Estate written by United States. Department of the Treasury and published by . This book was released on 1979 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:
