Download or read book Structuring Cross Border Transactions written by Mindy Herzfeld and published by Kluwer Law International B.V.. This book was released on 2022-10-11 with total page 435 pages. Available in PDF, EPUB and Kindle. Book excerpt: Structuring Cross-Border Transactions: U.S. Tax Considerations The U.S. international tax provisions that impact cross-border transactions are far-reaching. In recent years, the rules have become more complex, less systematic, and more difficult to make sense of. In this helpful book, a well-known author and practitioner demystifies many of the structuring questions implicated in inbound and outbound cross-border investments, acquisitions, and joint ventures, exposing traps and planning opportunities and showing how the rules really operate in specific fact patterns. All key aspects of structuring a cross-border transaction are analyzed, including: anti-deferral regimes (subpart F and global intangible low-taxed income (GILTI)); how check-the-box (CTB) regulations can maximize tax benefits and minimize tax inefficiencies; how the indirect foreign tax credit provides opportunities for tax beneficial planning; U.S. tax-free reorganization rules as they apply in the cross-border area; U.S. anti-inversion rules that affect cross-border deals; effect of anti-hybrid rules; concerns of particular classes of investors that will influence the form of a transaction; and typical points of friction between buyers and sellers in the cross-border context. Detailed examples, with financial metrics included, help guide decision making at every step and assist in the understanding of key drivers materially impacting results. Treaty considerations and implications are discussed throughout. This book fills a big gap in the tax literature by providing a guide for practitioners from any country who need to understand the U.S. tax consequences of a particular transaction. Its focus on how U.S. tax law affects the ways in which transactions are put together in the real world, and its in-depth analysis of how U.S. tax provisions interrelate and interact with foreign tax rules will prove of immeasurable value to corporate lawyers, finance professionals, and others active in cross-border mergers and acquisitions. It will become an indispensable reference tool for transactional tax practitioners.
Download or read book The Law of Cross border Business Transactions written by Lutz-Christian Wolff and published by Kluwer Law International. This book was released on 2018 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Law of Cross-Border Business Transactions aims at giving a structured introduction to the law and practice of investment deals (e.g., greenfield projects, M&As and hybrid forms) and of non-investment transactions (e.g., trade, technology transfer and services). Cross-border business deals are nowadays routine matters for business entities all over the world and the related legal aspects are becoming more and more complex. This book provides extensive general background information. It also covers numerous specific issues of relevance in the context of cross-border projects. Substantive law issues, procedural aspects and skills-related considerations such as contract drafting, structuring options and cross-cultural lawyering techniques are included, adding up to an unusually comprehensive and useful guide in the field. What's in this book: The author describes a wide spectrum of transaction types. He explains underlying principles from a conceptual and a comparative point of view with a focus on transactional issues, using case studies from a variety of jurisdictions to demonstrate the significance of particular aspects in the context of multi-jurisdictional legal practice. Among much else, topics include the following: international lawyering and cultural diversity; lex mercatoria; conflict of laws; letters of intent, position papers, heads of agreement, confidentiality and exclusivity agreements; structure and contents of international contracts; e-contracts and smart contracts; protection of intellectual property rights and technology transfer; trade, countertrade and trade financing; insurance; agency and distributorship; greenfield investments and M&As; competition law and merger control; employment law; corporate governance and corporate social responsibility; international taxation; and dispute settlement and cross-border enforcement of awards. This second edition updates the discussion of the different topics comprehensively. It also expands many parts and adds sections in relation to new themes that have gained importance since the publication of the first edition. In particular, it addresses legal issues arising out of the digitalization of the global economy with a special focus on choice-of-law questions, smart contracts, e-bills of lading and online dispute settlement. It also draws attention to the impact of China's Belt and Road initiative, Brexit and the 'America First' foreign policy. How this will help you: Of special value is the author's precise guidance on drafting techniques and contract practice. The clarity of the presentation, the uncompromising consistency in terms of structure and a large body of references to primary and secondary sources presented in this edition ensure that legal professionals, business managers and academics as well as other interested parties can gain easy access to comprehensive and detailed information across jurisdictions.
Download or read book The Cross Border Family Wealth Guide written by Andrew Fisher and published by John Wiley & Sons. This book was released on 2017-01-24 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: Make sense of international personal finance with expat-specific expert advice The Cross-Border Family Wealth Guide is the long-awaited financial handbook for cross border families, with expert insight from a financial advisor who specializes in expat issues. Whether you're an American living abroad, or foreign-born and living in the U.S., this book demystifies the complex issues surrounding the worldwide tax system, international information reporting, sensible investments, international real estate, and retirement planning. When your wealth crosses international borders, managing even the most mundane financial affairs can become wrought with time-consuming complexity; moving money, opening accounts, dealing with currency risks and translation, and setting up investments suddenly involves a whole new set of rules and regulations. Your 401(k), IRA, or annuity must be handled properly to retain certain tax benefits, and retirement planning takes on a brand new dimension of difficulty. This book shows you how to navigate the maze to make sure your money keeps working for you. Real world examples illustrate solutions to common problems, and real, actionable advice gives you a solid plan for your next steps. While personal finance management is rarely simple, the recent crackdown on tax havens and increased tax collection vigilance has made things even more difficult for cross border families. This book answers your questions, and shines a light on the way forward to long-term financial security for international families. Navigate the complexities of international taxation Get specific guidance on retirement planning Make sense of how real estate fits into your financial picture Invest appropriately to maximize growth for the future Manage your assets and tax benefits across borders With the right know-how, cross border professionals can make sensible investment and financial planning decisions, but credible guidance is rare and difficult to find. Simple and practical, with targeted advice, The Cross-Border Family Wealth Guide is the international family's solution for avoiding financial confusion.
Download or read book Cross Border Mergers and Acquisitions written by Scott C. Whitaker and published by John Wiley & Sons. This book was released on 2016-04-18 with total page 469 pages. Available in PDF, EPUB and Kindle. Book excerpt: Navigate cross border M&A for a flawless integration execution Cross Border Mergers and Acquisitions is a practical toolbox for corporate strategy and development professionals dealing with the many challenges involved in cross border M&A. With a detailed discussion of key market specifics and broadly-applicable critical insight, this book demystifies the cross border M&A process and provides a host of practical tools that ease strategic implementation. A geographical overview explains the trends in major M&A markets including Australia, Brazil, China, Russia, the U.K., and the U.S., and industry-specific guidance covers Financial Services, Aerospace and Defense, Health Care, Tech, Manufacturing, and more. Leading experts relate lessons learned while managing actual PMI (post merger integration) processes, and the discussion of cultural impacts and specific situational needs provides deep insight into the type of leadership a flawless integration requires. Corporate restructuring and internationalization efforts are increasingly relying on cross border mergers and acquisitions. Strategies, motives, and consequences are a complex navigational minefield, but this insightful guide provides solid, actionable guidance for leading a successful integration. Understand the region-specific details that make an impact Overcome common challenges and manage complex deals Gain practical insight and valuable tools for leading integration Learn the most current best practices for PMI® processes Cross border M&A is complex, with myriad challenges and obstacles inherent to the situation. Successful integration and a smooth transition are critical, and there's little wiggle room—it's a situation where you have only one chance to get it right. Cross Border Mergers and Acquisitions is an essential guide to the process, with key tools for execution.
Download or read book Multidisciplinary Perspectives on Cross Border Trade and Business written by Asmat-Nizam Abdul-Talib and published by Business Science Reference. This book was released on 2021-12-13 with total page 335 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Cross border business transactions have become increasingly important due to new norms of doing business so this book captures the multi-faceted outlook on international business phenomena particularly when cross border businesses were severely affected by the worldwide pandemic"--
Download or read book General Explanation of the Tax Reform Act of 1986 written by and published by . This book was released on 1987 with total page 1412 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Corporate Income Taxes under Pressure written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2021-02-26 with total page 388 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
Download or read book Mergers Acquisitions and Other Restructuring Activities written by Donald DePamphilis and published by Academic Press. This book was released on 2009-09-22 with total page 787 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the fifth edition of this well-known text, Dr. DePamphilis explains the real world of mergers, acquisitions, and restructuring based on his academic knowledge and personal experiences with over 30 such deals himself. Important enhancements unique to the fifth edition: all 99 cases involve real-life deals made or announced within the last five years, extensive discussions of all current valuation techniques and their strengths and weaknesses, cross-border transactions analyzed and explained in detail, tax and legal issues covered comprehensively. - Focuses on the REAL WORLD, not just theory. The 99 case studies span every industry and dozens of countries and show how deals are done rather than just the theory behind them. All cases fully updated for this edition. Cases all involve transactions that have occurred or been announced within the past 3-5 years. - Extensive updating and enhanced content provided on reorganization, bankruptcy, and liquidation issues both inside and outside of bankruptcy court
Download or read book Cross Border Economic Cooperation Between China and Southeast Asian Countries written by Zanxin Wang and published by Springer Nature. This book was released on 2022-03-25 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book focuses on how to promote cross-border economic cooperation in the context of China national strategy including BRI. This book summarizes the existing regional economic development theories and sorts out the relevant theories of cross-border economic cooperation. Then, it analyzes the industrial development of China's southwestern border and neighboring countries, the main reasons of rural household poverty in the border ethnic areas by means of empirical methods, and proposes corresponding policy implications. Also, it explores the current border investment and trade policies of China, and compares the similarities and differences between China and Vietnam, and Laos and Myanmar.
Download or read book Mergers Acquisitions and Other Restructuring Activities written by Donald DePamphilis and published by Academic Press. This book was released on 2011-08-22 with total page 784 pages. Available in PDF, EPUB and Kindle. Book excerpt: Two strengths distinguish this textbook from others. One is its presentation of subjects in the contexts wherein they occur. The other is its use of current events. Other improvements have shortened and simplified chapters, increased the numbers and types of pedagogical supplements, and expanded the international appeal of examples.
Download or read book Cross border Trade and the Parallel Currency Market written by Yahaya Hashim and published by Nordic Africa Institute. This book was released on 1999 with total page 128 pages. Available in PDF, EPUB and Kindle. Book excerpt: The authors of this study challenge the assumptions of the World Bank that the expansion in informal cross-border trade is a vindication of the market-liberalizing thrust of structural adjustment, and that adjustment policies have improved the effectiveness of an "independent" bourgeoisie that is emerging out of this trade as an agent of regional integration. Instead, they make the case for the adoption of what they call a "development approach" for tapping the benefits of the informal currency markets, as an alternative to the "market coercion" of structural adjustment.
Download or read book Transnational Legal Processes written by Michael Likosky and published by Cambridge University Press. This book was released on 2002-04 with total page 548 pages. Available in PDF, EPUB and Kindle. Book excerpt: This work comprises 24 linked essays by leading transatlantic scholars in international law and the social sciences examining the sociolegal aspects of multi-jurisdictional legal techniques and trans-jurisdictional social phenomena. The contributors bring a range of disciplinary expertises including anthropology, economics, law and sociology to bear on key questions raised by transnational legal processes. The pieces explore legal developments in multiple territories including Africa, Asia, Latin America and the United States. The volume is designed as a general reader for courses on law and globalisation and related studies. The collection is made up of four parts, each addressing a central theme in transnational law and legal action (law-making and compliance), human rights, commerce and governance. The essays discuss such diverse problems as: the role of foreign actors in the ethnic conflicts of Kosovo and Rwanda; the power the United States and the UK wield over international capital markets; and the adaptability of existing public international law to deal with the challenges wrought by globalisation.
Download or read book Simple Fair and Pro growth written by United States. President's Advisory Panel on Federal Tax Reform and published by . This book was released on 2006 with total page 304 pages. Available in PDF, EPUB and Kindle. Book excerpt: The official account of the advisory panel formed by Presi-dent George W. Bush to identify major problems in the U.S.Federal Tax Code and to recommend options to make the codesimpler, fairer and more conducive to economic growth. Thepanel's report was submitted to U.S. Secretary of the Trea-sury John W. Snow on Nov. 1, 2005. Chaired by Connie MackIII, the panel recommended 2 reform options: the SimplifiedIncome Tax Plan & the Growth & Investment Tax Plan.
Download or read book Cross Border Resource Management written by Rongxing Guo and published by Elsevier. This book was released on 2005-07-25 with total page 301 pages. Available in PDF, EPUB and Kindle. Book excerpt: This essay is about the management of natural and environmental resources in cross-border areas. It explores a group of geographical, political, legal, economic and cultural factors that arise when political units (such as sovereign countries, dependent states and other administrative units) seek to utilize natural and environmental resources efficiently and equitably while minimizing the resultant damages (for example, prevention of resource degradation and preservation of the physical environment). * Examines various types of cross-border areas at both international and sub-national levels throughout the world as well as their geographical, political, economic and cultural influences on the cross-border resource management * Uses the latest international and area data, resulting in new findings for cross-border environmental activities * Contains a large number of case studies throughout the world including four in-depth case studies of cross-border resource management
Download or read book Transnational Legal Orders written by Terence C. Halliday and published by Cambridge University Press. This book was released on 2015-01-19 with total page 559 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transnational Legal Orders offers an empirically grounded approach to the emergence of legal orders beyond nation-states that reframes the study of law and society.
Download or read book Introduction to the Law of Double Taxation Conventions written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2021-04-01 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.
Download or read book The Structure of Financial Regulation written by David Mayes and published by Routledge. This book was released on 2007-01-18 with total page 456 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines the area of financial regulation in the banking sector. Editors Mayes and Wood bring together such acadmics as Charles Goodhart, Charles Calomiris and Kern Alexander whose expertise shines through this volume to provide a reference tool for researchers, students and bankers themselves which will prove invaluable.
