Download or read book Tolley s Taxation of Corporate Debt Foreign Exchange and Derivative Contracts written by David Southern and published by Bloomsbury Professional. This book was released on 2004 with total page 578 pages. Available in PDF, EPUB and Kindle. Book excerpt: Taxation of Corporate Debt, Foreign Exchange and Derivative Contracts Seventh Edition considers the practical implications of the legislation in loan relationships and derivative contracts made by the Finance Act 2002, and the related rules for foreign exchange. This comprehensive guide covers: * Changes in legislation and practice up to December 2003, including the Finance Act 2003 * FRED 23, 24 and 30 * The Pre-Budget Statement * All relevant legislation, cases and background information * Case law developments. This book also contains numerous worked examples explaining the interaction between tax codes, accounting framework, corporate transactions and various planning issues to aid further understanding of the material covered. Providing the answers to all your questions regarding corporate debt and derivative contracts, Taxation of Corporate Debt, Foreign Exchange and Derivative Contracts Seventh Edition includes: * Loan relationships: concepts and application, structured capital finance, debt securities and acquisitions and disposals * Foreign exchange: overview of the 1993 Finance Act tax regime, Finance Act 2002 and local currency companies * Derivative contracts: scope and definition, computation of profits and anti-avoidance rules* Stock lending and repos: detailed analysis of legislation including Finance Act 2003 changes. This is your complete reference source to planning and restructuring your financial transactions to avoid potential and unexpected tax liabilities.
Download or read book Taxation of Loan Relationships and Derivative Contracts written by David Southern and published by Bloomsbury Professional. This book was released on 2007 with total page 773 pages. Available in PDF, EPUB and Kindle. Book excerpt: Formerly known as Taxation of Corporate Debt, Foreign Exchange and Derivative Contracts, Taxation of Loan Relationships and Derivative Contracts 8th edition has been comprehensively revised and updated in light of the recent major developments in the subject. The expert guidance and clearly presented practical information contained in the book demonstrate exactly how the developments in this complex field will affect the tax treatment of company financing. Corporate tax practitioners with a copy of Taxation of Loan Relationships and Derivative Contracts 8th edition on their desk will be able to handle their clients' finance arrangements with confidence and accuracy.
Download or read book The Taxation of Derivatives written by and published by . This book was released on 1994 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Derivatives written by and published by . This book was released on 1995 with total page 642 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation Aspects of Currency Fluctuations written by Jill C. Pagan and published by Butterworth-Heinemann. This book was released on 1983 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: Taxation of currency gains and losses considered.
Download or read book Markets for Corporate Debt Securities written by T. Todd Smith and published by International Monetary Fund. This book was released on 1995-07-01 with total page 88 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper surveys markets for corporate debt securities in the major industrial countries and the international markets. The discussion includes a comparison of the sizes of the markets for various products, as well as the key operational, institutional, and legal features of primary and secondary markets. Although there are some signs that debt markets may be emphasized in the future by some countries, it remains true that North American debt markets are the most active and liquid in the world. The international debt markets are, however, growing in importance. The paper also investigates some of the reasons for the underdevelopment of domestic bond markets and the consequences of firms shifting their debt financing needs from banks to securities markets.
Download or read book Budget options written by United States. Congressional Budget Office and published by . This book was released on 1977 with total page 380 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book A Review of Taxes and Corporate Finance written by John R. Graham and published by Now Publishers Inc. This book was released on 2006 with total page 136 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Review of Taxes and Corporate Finance investigates the consequences of taxation on corporate finance focusing on how taxes affect corporate policies and firm value. A common theme is that tax rules affect corporate incentives and decisions. A second emphasis is on research that describes how taxes affect costs and benefits. A Review of Taxes and Corporate Finance explores the multiple avenues for taxes to affect corporate decisions including capital structure decisions, organizational form and restructurings, payout policy, compensation policy, risk management, and the use of tax shelters. The author provides a theoretical framework, empirical predictions, and empirical evidence for each of these areas. Each section concludes with a discussion of unanswered questions and possible avenues for future research. A Review of Taxes and Corporate Finance is valuable reading for researchers and professionals in corporate finance, corporate governance, public finance and tax policy.
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 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 Taxation of Loan Relationships and Derivative Contracts written by David Southern and published by Bloomsbury Publishing. This book was released on 2017-01-13 with total page 717 pages. Available in PDF, EPUB and Kindle. Book excerpt: Taxation of Loan Relationships and Derivative Contracts, Tenth Edition, is updated in line with the Finance Act 2015 which brings in significant changes to the loan relation rules. In addition, it includes changes to both UK and International Accounting Standards. This new edition covers developments in the Basic Erosion and Profit Shifting (BEPs) project and the related new climate and wider concept of tax avoidance (GAAR). The chapters covering accounting framework, reorganisations and international aspects have been significantly updated since the previous edition and new chapters have been added with a summary of all relevant cases and a chapter covering Islamic Finance. Covers the following: The Taxation of Finance Accounting under IFRS and Modified UK GAAP The Scheme of the Legislation Loan Relationships: Scope and Definition Loan Relationships: General Computational Provisions Loan Relationships: Special Computational Provisions Impairment Losses Foreign Exchange and Hedging/Deferral Interest Securities Reorganisations, Acquisitions and Disposals Special Companies Derivative Contracts – Definition and Scope Derivative Contracts – Measurement of Profits Embedded Derivatives Worldwide Debt Cap Transfer Pricing Stock Lending and Repos International Aspects Islamic Finance Cases Appendices
Download or read book Taxation of Derivatives and Cryptoassets written by Oktavia Weidmann and published by Kluwer Law International B.V.. This book was released on 2024-06-10 with total page 676 pages. Available in PDF, EPUB and Kindle. Book excerpt: Derivatives stand at the forefront of financial innovation, continually evolving to accommodate new asset classes and risk categories. In the past decade, the growing popularity of cryptoassets and ESG investments has sparked the development of a variety of innovative investment strategies and risk management tools, including crypto and ESG derivatives and related structured products. This new edition has similarly evolved. Using illustrative examples, it provides a comprehensive analysis of the key tax issues associated with derivatives and cryptoassets in domestic and cross-border transactions and presents approaches that tax legislators could adopt to solve them. The new edition also comments on recent trends in global tax policy, such as the OECD Base Erosion and Profit Shifting (BEPS) 1.0 and 2.0 projects. Throughout the book, specific references are made to UK, German, and Swiss tax law. The updated edition addresses the following topics: economic and financial properties of derivatives and cryptoassets; definition of derivatives for tax purposes and its application to crypto derivatives and ESG derivatives, among others; accounting treatment of derivatives and cryptoassets under IFRS, UK, German and US GAAP; current tax legislation and policy alternatives to the taxation of derivatives and cryptoassets; characterisation of derivatives gains and losses as income or capital, and equity or debt; accounting and taxation treatment of hedging transactions involving derivatives or cryptoassets; accounting and taxation rules applying to structured products and hybrid instruments, including crypto and ESG-linked structured products; withholding taxes on derivatives and the concept of beneficial ownership in domestic and cross-border transactions; and anti-avoidance legislation applying to derivatives and cryptoassets, including the domestic law implementation of BEPS Action 2, the EU Anti-Tax Avoidance Directives (ATAD I and II), the tax transparency rules for cryptoassets (DAC8) and Pillar Two. This comprehensive book analyses recent developments in three intertwined areas of expertise: financial products, accounting and tax law. It will be a valuable resource to tax professionals in their daily practice of advising companies, banks and investment funds. It will also be of interest to government officials and researchers engaged in the taxation of derivatives, cryptoassets, and ESG investment products.
Download or read book Financial sector taxation written by [Anonymus AC08741538] and published by . This book was released on 2010 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The global economic and financial crisis has created important needs for fiscal consolidation. This document analyses potential instruments to raise additional tax revenues from the financial sector. The first section reviews the current policy objectives related to the taxation of the financial sector. The second section sheds some light on the current tax treatment of the financial sector. The third section discusses potential tax instruments to reach the goals. The fourth and fifth section respectively assess the advantages and drawbacks of a Financial Transaction Tax and a Financial Activities Tax."--Editor.
Download or read book Pouring Oil on Fire Interest Deductibility and Corporate Debt written by Pietro Dallari and published by International Monetary Fund. This book was released on 2018-12-07 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper investigates the role of tax incentives towards debt finance in the buildup of leverage in the nonfinancial corporate (NFC) sector, using a large firm-level dataset. We find that so-called debt bias is a significant driver of leverage, for both small and medium-sized enterprises and larger firms, with its effect accounting for about a quarter of leverage. The strength of this effect differs with firm size, the availability of collateral, income and income volatility, cash flow, and capital intensity. We conclude that leveling the playing field between debt and equity finance through tax policy reform would decrease NFC leverage, reducing economic risks posited by leverage.
Download or read book Financial Sector Debt Bias written by Ms.Oana Luca and published by International Monetary Fund. This book was released on 2016-11-10 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt: Most tax systems create a tax bias toward debt finance. Such debt bias increases leverage and may negatively affect financial stability. This paper models and estimates debt bias in the financial sector, and present novel estimates for investment banks and non-bank financial intermediaries such as finance and insurance companies. We find debt bias to be pervasive, explaining as much as 10 percent of total leverage for regular banks and 20 percent for investment banks, with the effects most pronounced before the global financial crisis. Going forward, debt bias is likely to once again gain prominence as a key driver of leverage decisions, underscoring the importance of policy reform at this juncture.
Download or read book The Political Economy of Corporation Tax written by John Snape and published by Bloomsbury Publishing. This book was released on 2011-12-09 with total page 203 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
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.
