Download or read book Taxation of Corporate Debt and Derivatives written by Julian Ghosh and published by . This book was released on 2009-04-14 with total page 800 pages. Available in PDF, EPUB and Kindle. Book excerpt: Formerly known as Taxation of Loan Relationships and Derivatives, this publication was re-launched and fully updated in April 2009. Offering invaluable tax planning help for the tax specialist and with its easy to use subject index and cross-referencing, 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
Download or read book Ghosh Johnson and Miller on the Taxation of Corporate Debt and Derivatives written by Julian Ghosh and published by . This book was released on 2009 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation of Loan Relationships and Derivative Contracts written by David Southern and published by A&C Black. This book was released on 2012-06-01 with total page 657 pages. Available in PDF, EPUB and Kindle. Book excerpt: The ninth edition of this well-established work offers comprehensive coverage of all aspect of the taxation of loan relationships and derivative contracts in the UK. It covers the UK's IAS 32/39 and FRS 25/26, loan relationships under IAS, impairment losses and connected company rules, the derivative contracts rules, bifurcation of convertibles, transfer pricing domestic and international, the disregard rules on tax hedging, matching and functional currencies, reconstructions and mergers, repos and stock lending, anti-avoidance rules, corporate debt, loan relationships, derivative contracts, securities taxation, and debt impairment. Particular emphasis is placed on providing worked examples and planning guidance.
Download or read book Tolley s Taxation of Corporate Debt Foreign Exchange and Derivative Contracts written by David Southern and published by . This book was released on 2002 with total page 536 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Corporation Tax written by and published by . This book was released on 2014 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Taxation of Equity Derivatives and Structured Products written by T. Rumble and published by Springer. This book was released on 2002-12-03 with total page 265 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Taxation of Investment Derivatives written by Antti Laukkanen and published by IBFD. This book was released on 2007 with total page 487 pages. Available in PDF, EPUB and Kindle. Book excerpt: This dissertation aims to provide a comprehensive overview of the taxation of investment derivatives and the relationship between the derivatives and the accrual and realization methods. Investment derivatives, such as convertible bonds, include an initial investment and a derivative (an option) to buy or sell or to participate in the value movements of some underlying property. The principal focus of this study is on three universal tax issues, namely valuation, timing and the taxation of unrealized gains. As a common principle, interest income and capital gains are treated more similarly in corporate taxation than in individual taxation. Moreover, the taxation of financial instruments is currently in a turn-around phase in several countries, not least because of the implementation of the IFRS rules in accounting and the related fair value principle. The obligation to use fair values in accounting apparently motivates tax legislators to strive to use the same principles in taxation as well. The comparative method plays a major role in this study by examining the tax legislations and the tax practices of different countries. An in-depth analysis of the similarities and differences of tax laws and practices in the United States, the United Kingdom, Germany, Finland and Sweden is provided. This is of particular interest as the underlying components, single and often specified financial derivatives, are basically identical. While this study does not deal with individual tax treaties or bilateral transactions, the OECD Model is scrutinized in order to highlight the underlying principles of the given recommendations, especially with respect to interest income and capital gains. Due to the increasing importance of IFRS rules in accounting, the study is not limited to tax law, but also looks at issues from the perspective of finance, accounting and economics.
Download or read book Modernising the Taxation of Corporate Debt and Derivative Contracts written by and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Tax Elasticity of Corporate Debt written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2011-04-01 with total page 29 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although the empirical literature has long struggled to identify the impact of taxes on corporate financial structure, a recent boom in studies offers ample support for the debt bias of taxation. Yet, studies differ considerably in effect size and reveal an equally large variety in methodologies and specifications. This paper sheds light on this variation and assesses the systematic impact on the size of the effects. We find that, typically, a one percentage point higher tax rate increases the debt-asset ratio by between 0.17 and 0.28. Responses are increasing over time, which suggests that debt bias distortions have become more important.
Download or read book The Use of Derivatives in Tax Planning written by Frank J. Fabozzi, CFA and published by John Wiley & Sons. This book was released on 1998-06-20 with total page 320 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Taxation of Corporate Debt and Financial Instruments written by David Southern and published by . This book was released on 2001-12-30 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Taxation of Derivatives written by Oktavia Weidmann and published by Kluwer Law International B.V.. This book was released on 2015-07-16 with total page 439 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Tax exempt Derivatives written by Steven D. Conlon and published by American Bar Association. This book was released on 1994 with total page 414 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation of Loan Relationships Financial Instruments and Foreign Exchange written by Julian Ghosh and published by Tolley. This book was released on 1998 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication offers invaluable tax planning help for the tax specialist and with its easy to use subject index and cross-referencing, it 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 involved.
Download or read book Tolley s Taxation of Corporate Debt and Financial Instruments written by David Southern and published by . This book was released on 2001 with total page 497 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation of Corporate Debt Finance written by Yuri F. R. Grbich and published by . This book was released on 1991 with total page 295 pages. Available in PDF, EPUB and Kindle. Book excerpt: Collection of 12 papers which form a guide to current rules and practices in respect of taxation of corporate finance arrangements following bank deregulation. Includes tables of cases, statutes and income tax rulings. Part of the TRevenue and Company Law Practice' series.
Download or read book The Tax Elasticity System of Corporate Debt written by Ruud A. de Mooij and published by . This book was released on 2011 with total page 27 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although the empirical literature has long struggled to identify the impact of taxes on corporate financial structure, a recent boom in studies offers ample support for the debt bias of taxation. Yet, studies differ considerably in effect size and reveal an equally large variety in methodologies and specifications. This paper sheds light on this variation and assesses the systematic impact on the size of the effects. We find that, typically, a one percentage point higher tax rate increases the debt-asset ratio by between 0.17 and 0.28. Responses are increasing over time, which suggests that debt bias distortions have become more important.
