Download or read book The Tax Treatment of Contingent Options written by Matthew A. Stevens and published by . This book was released on 2004 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Ascertaining whether a particular financial instrument is an option is important not only for determining the tax treatment of payments made under that instrument, but also for determining the tax consequences of other transactions in which the taxpayer may have engaged. This article discusses the tax treatment of financial instruments that take the form of options but prohibit the exercise of the option unless a specified event occurs. While a number of cases and rulings have dealt with the taxation of contingent options in the contexts of particular transactions, the existing authorities have not set forth a comprehensive theory for analyzing these instruments. In this article, the author proposes a framework for determining the tax treatment of contingent options. To that end, the article first gives several examples of contingent options. Second, the article analyzes the cases and rulings that govern the treatment of contingent options. Third, the article applies the principles of the cases and rulings to the examples of contingent options referred to above. Finally, the article concludes that whether a particular contingent option would be treated as an option for tax purposes would depend largely on the policy considerations that are relevant to the code provision for which the determination was being made.
Download or read book U S Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 498 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 General Explanation of Tax Legislation Enacted in written by and published by Government Printing Office. This book was released on 2005 with total page 652 pages. Available in PDF, EPUB and Kindle. Book excerpt: JCS-5-05. Joint Committee Print. Provides an explanation of tax legislation enacted in the 108th Congress. Arranged in chronological order by the date each piece of legislation was signed into law. This document, prepared by the staff of the Joint Committee on Taxation in consultation with the staffs of the House Committee on Ways and Means and the Senate Committee on Finance, provides an explanation of tax legislation enacted in the 108th Congress. The explanation follows the chronological order of the tax legislation as signed into law. For each provision, the document includes a description of present law, explanation of the provision, and effective date. Present law describes the law in effect immediately prior to enactment. It does not reflect changes to the law made by the provision or subsequent to the enactment of the provision. For many provisions, the reasons for change are also included. In some instances, provisions included in legislation enacted in the 108th Congress were not reported out of committee before enactment. For example, in some cases, the provisions enacted were included in bills that went directly to the House and Senate floors. As a result, the legislative history of such provisions does not include the reasons for change normally included in a committee report. In the case of such provisions, no reasons for change are included with the explanation of the provision in this document. In some cases, there is no legislative history for enacted provisions. For such provisions, this document includes a description of present law, explanation of the provision, and effective date, as prepared by the staff of the Joint Committee on Taxation. In some cases, contemporaneous technical explanations of certain bills were prepared and published by the staff of the Joint Committee. In those cases, this document follows the technical explanations. Section references are to the Internal Revenue Code unless otherwise indicated.
Download or read book United States Code written by United States and published by . This book was released on 2013 with total page 1506 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.
Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Download or read book List of Original Issue Discount Instruments written by United States. Internal Revenue Service and published by . This book was released on 1985 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Options to Improve Tax Compliance and Reform Tax Expenditures written by United States. Congress. Joint Committee on Taxation and published by Joint Committee on Taxation. This book was released on 2005 with total page 450 pages. Available in PDF, EPUB and Kindle. Book excerpt: Describes proposals to to reduce the size of the Federal tax gap by curtaling tax shelters, closing unintended loopholes, addressing other areas of noncompliance with current tax law, and reforming certain areas of tax expenditures.
Download or read book Sales of Personal Property written by Ernest Bancroft Conant and published by . This book was released on 1914 with total page 150 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 Tax Reform and the Tax Treatment of Financial Products written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 2011 with total page 548 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Credit Derivatives and Structured Credit Trading written by Vinod Kothari and published by John Wiley & Sons. This book was released on 2011-12-15 with total page 523 pages. Available in PDF, EPUB and Kindle. Book excerpt: Credit derivatives as a financial tool has been growing exponentially from almost nothing more than seven years ago to approximately US$5 trillion deals completed by end of 2005. This indicates the growing importance of credit derivatives in the financial sector and how widely it is being used these days by banks globally. It is also being increasingly used as a device of synthetic securitisation. This significant market trend underscores the need for a book of such a nature. Kothari, an undisputed expert in credit derivatives, explains the subject matter using easy-to-understand terms, presents it in a logical structure, demystifies the technical jargons and blends them into a cohesive whole. This revised book will also include the following: - New credit derivative definitions - New features of the synthetic CDO market - Case studies of leading transactions of synethetic securitisations - Basle II rules - The Consultative Paper 3 has significantly revised the rules, particularly on synthetic CDOs - Additional inputs on legal issues - New clarifications on accounting for credit derivatives/credit linked notes
Download or read book Circular E Employer s Tax Guide Publication 15 For Use in 2021 written by Internal Revenue Service and published by . This book was released on 2021-03-04 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt: Employer's Tax Guide (Circular E) - The Families First Coronavirus Response Act (FFCRA), enacted on March 18, 2020, and amended by the COVID-related Tax Relief Act of 2020, provides certain employers with tax credits that reimburse them for the cost of providing paid sick and family leave wages to their employees for leave related to COVID‐19. Qualified sick and family leave wages and the related credits for qualified sick and family leave wages are only reported on employment tax returns with respect to wages paid for leave taken in quarters beginning after March 31, 2020, and before April 1, 2021, unless extended by future legislation. If you paid qualified sick and family leave wages in 2021 for 2020 leave, you will claim the credit on your 2021 employment tax return. Under the FFCRA, certain employers with fewer than 500 employees provide paid sick and fam-ily leave to employees unable to work or telework. The FFCRA required such employers to provide leave to such employees after March 31, 2020, and before January 1, 2021. Publication 15 (For use in 2021)
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 Film Financing and Television Programming written by and published by . This book was released on 1996 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book General Explanation of the Tax Reform Act of 1986 written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 1987 with total page 1404 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Farm Corporations and Their Income Tax Treatment written by United States. Department of Agriculture. Economic Research Service and published by . This book was released on 1974 with total page 150 pages. Available in PDF, EPUB and Kindle. Book excerpt:
