International Tax Aspects of Sovereign Wealth Investors

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9041194339
Total Pages : 378 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis International Tax Aspects of Sovereign Wealth Investors by : Richard Snoeij

Download or read book International Tax Aspects of Sovereign Wealth Investors written by Richard Snoeij and published by Kluwer Law International B.V.. This book was released on 2018-04-18 with total page 378 pages. Available in PDF, EPUB and Kindle. Book excerpt: An increasing number of States have entered the market looking to invest resources in foreign assets. This emergence of States acting as investors, managing the wealth of a nation and competing in the marketplace with private investors, has attracted growing and wide attention. This book is the first in-depth analysis of the international tax aspects of sovereign wealth investors, and serves as a comprehensive guide to designing tax policy, from a source State perspective, toward inbound sovereign wealth investment. Drawing on a wide range of relevant sources, including international instruments, domestic tax legislation, administrative practice, (international) case law and the writings of highly qualified publicists, the author fully addresses the following aspects of the subject: – the definition, functions, legal form, governance, home State tax status, etc. of sovereign wealth investors; – tax policy considerations and objectives (i.e., neutrality, equity and international attractiveness) from a source State perspective vis-à-vis foreign sovereign wealth investors; and – the potential impact of the sovereign immunity principle, bilateral tax treaties and European (Union) law on source States’ ability to achieve these tax policy objectives in relation to foreign sovereign wealth investors. The conceptual framework developed by the author will greatly assist source States in introducing new tax policy or in evaluating or reconsidering their existing tax policy vis-à-vis foreign sovereign wealth investors. In addition, practitioners, academics and (home States of) sovereign wealth investors will welcome this first authoritative analysis of an important but insufficiently understood subject in international tax.

Sovereign Wealth Funds

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Publisher :
ISBN 13 : 9781402414817
Total Pages : 0 pages
Book Rating : 4.4/5 (148 download)

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Book Synopsis Sovereign Wealth Funds by : Leonard Schneidman

Download or read book Sovereign Wealth Funds written by Leonard Schneidman and published by . This book was released on 2010 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: In Sovereign Wealth Funds, noted international tax lawyer Leonard Schneidman has assembled an array of essays, authored by a global collection of subject area experts, designed to explore three key aspects of SWFs: their regulation and governance, investment behavior, and taxation. You'll quickly discover this work to be the highly useful tool you and your clients need to assess the SWF phenomenon and its practical legal, tax and financial implications.

Taxation of Investment Funds in the European Union

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Publisher : IBFD
ISBN 13 : 9076078750
Total Pages : 427 pages
Book Rating : 4.0/5 (76 download)

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Book Synopsis Taxation of Investment Funds in the European Union by : Tomi Viitala

Download or read book Taxation of Investment Funds in the European Union written by Tomi Viitala and published by IBFD. This book was released on 2005 with total page 427 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.

The Law of Sovereign Wealth Funds

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Publisher : Edward Elgar Publishing
ISBN 13 : 0857932365
Total Pages : 192 pages
Book Rating : 4.8/5 (579 download)

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Book Synopsis The Law of Sovereign Wealth Funds by : Fabio Bassan

Download or read book The Law of Sovereign Wealth Funds written by Fabio Bassan and published by Edward Elgar Publishing. This book was released on 2011 with total page 192 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bassan provides a remarkable compendium on the relevant laws, regulations, and standards affecting sovereign wealth funds. These institutions are now at the very centre of the global financial system and demand greater appreciation of their distinctive qualities as well as their likely implications for nation-states and the global economy. Bassan s book is a unique contribution to understanding the governance and regulation of these institutions and will be an important resource book for those who must grapple with the growing power and global scope of these institutions. Gordon L. Clark, University of Oxford, UK and Monash University, Australia This book covers a true vacuum in international legal literature thanks to its multi-facet in-depth analysis of SWFs, a new type of protagonists of transnational investments in the global economy. It analyses critically the various approaches put forth to pinpoint real nature, legal set-up, relevant features in the diverse operating activity of SWF in the perspective of addressing the issue of the most appropriate regulation that would ensure two apparently conflicting goals: the protection of SWF investments and of host states legitimate concerns for vital national political or economic interests and the diverse activities. On this basis, the author reviews the various international hard and soft law regulations proposed and the relevance of existing disciplines including Bilateral Investment Treaties. The full coverage of the issue of sovereign immunity in respect of SWF is a useful completion of the author s analysis. Giorgio Sacerdoti, Bocconi University, Italy This book provides a definition and classification for Sovereign Wealth Funds (SWFs) and discusses its phenomenon within the legal context. It identifies the rules applicable to SWFs and focuses on the bilateral relationships between states. In eight extensive chapters, Fabio Bassan considers whether SWFs may enjoy immunity with respect to host state measures as well as protection in Bilateral Investment Treaties Written from an international law perspective, The Law of Sovereign Wealth Funds will appeal to students of international business, international organizations, banks and governments.

Economic and U.S. Income Tax Issues Raised by Sovereign Wealth Fund Investment in the United States

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Publisher :
ISBN 13 :
Total Pages : 129 pages
Book Rating : 4.:/5 (1 download)

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Book Synopsis Economic and U.S. Income Tax Issues Raised by Sovereign Wealth Fund Investment in the United States by :

Download or read book Economic and U.S. Income Tax Issues Raised by Sovereign Wealth Fund Investment in the United States written by and published by . This book was released on 2008 with total page 129 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Sovereign Wealth Funds

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Author :
Publisher : Princeton University Press
ISBN 13 : 0691142297
Total Pages : 236 pages
Book Rating : 4.6/5 (911 download)

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Book Synopsis Sovereign Wealth Funds by : Gordon L. Clark

Download or read book Sovereign Wealth Funds written by Gordon L. Clark and published by Princeton University Press. This book was released on 2013-07-21 with total page 236 pages. Available in PDF, EPUB and Kindle. Book excerpt: The worldwide rise of sovereign wealth funds is emblematic of the ongoing transformation of nation-state economic prospects. Sovereign Wealth Funds maps the global footprints of these financial institutions, examining their governance and investment management, and issues of domestic and international legitimacy. Through a variety of case studies--from the China Investment Corporation to the funds of several Gulf states--the authors show that the forces propelling the adoption and development of sovereign wealth funds vary by country. The authors also show that many of these investment institutions have identifiable commonalities of form and function that match the core institutions of Western financial markets. The authors suggest that the international legitimacy of sovereign wealth funds is based on the degree to which their design and governance match Western expectations about investment management. Undercutting commonplace assumptions about the emerging world of the twenty-first century, the authors demonstrate that even small countries with large and globally oriented sovereign wealth funds are likely to play a significant role in international relations. Sovereign Wealth Funds considers how such financial organizations have altered not only the face of finance, but also the international geopolitical landscape.

Research Handbook on Sovereign Wealth Funds and International Investment Law

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Author :
Publisher : Edward Elgar Publishing
ISBN 13 : 1781955204
Total Pages : 464 pages
Book Rating : 4.7/5 (819 download)

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Book Synopsis Research Handbook on Sovereign Wealth Funds and International Investment Law by : Fabio Bassan

Download or read book Research Handbook on Sovereign Wealth Funds and International Investment Law written by Fabio Bassan and published by Edward Elgar Publishing. This book was released on 2015-06-29 with total page 464 pages. Available in PDF, EPUB and Kindle. Book excerpt: Research on the role of sovereign investments in a time of crisis is still unsatisfactory. This Research Handbook illustrates the state of the art of the legal investigation on sovereign investments, filling necessary gaps in previous research. Current

The Oxford Handbook of Sovereign Wealth Funds

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Publisher : Oxford University Press
ISBN 13 : 0198754809
Total Pages : 737 pages
Book Rating : 4.1/5 (987 download)

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Book Synopsis The Oxford Handbook of Sovereign Wealth Funds by : Douglas Cumming

Download or read book The Oxford Handbook of Sovereign Wealth Funds written by Douglas Cumming and published by Oxford University Press. This book was released on 2017 with total page 737 pages. Available in PDF, EPUB and Kindle. Book excerpt: Sovereign Wealth Funds have become increasingly powerful and influential investors. Their increasing role, and unusual character as both political and market actors, raise a number of issues with regard to finance, politics, regulation, and international business. This handbook draws together the growing but fragmented research on SWFs.

Sovereign Wealth Funds

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Publisher : Oxford University Press, USA
ISBN 13 : 0199752117
Total Pages : 232 pages
Book Rating : 4.1/5 (997 download)

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Book Synopsis Sovereign Wealth Funds by : Christopher Balding

Download or read book Sovereign Wealth Funds written by Christopher Balding and published by Oxford University Press, USA. This book was released on 2012 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt: Sovereign wealth funds are a growing and dynamic force in international finance. This is the first book to compile a history of sovereign wealth funds, recounting the Abu Dhabi Investment Authority's involvement with the scandal-plagued BCCI bank and Chinese arms exports to Iran. In a straightforward and accessible style, the author examines the complex and amazing growth of an unknown group of investors controlling trillions of dollars worldwide.

Sovereign Wealth Funds

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Publisher : International Monetary Fund
ISBN 13 : 1475514476
Total Pages : 34 pages
Book Rating : 4.4/5 (755 download)

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Book Synopsis Sovereign Wealth Funds by : Abdullah Al-Hassan

Download or read book Sovereign Wealth Funds written by Abdullah Al-Hassan and published by International Monetary Fund. This book was released on 2013-11-11 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper presents in a systematic (normative) manner the salient features of a SWF‘s governance structure, in relation to its objectives and investment management that can ensure its efficient operation and enhance its financial performance. In this context, it distinguishes among the various governing bodies and analyzes key aspects of the investment policy and setting of the risk tolerance level in order to ensure consistent risk-bearing capacity and greater accountability. Further, it discusses the important role of SWFs in macroeconomic management and the need for close coordination with other macroeconomic and financial policies as well as their role in global financial stability.

Norway’s Sovereign Wealth Fund

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Publisher : Springer Nature
ISBN 13 : 3030741079
Total Pages : 267 pages
Book Rating : 4.0/5 (37 download)

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Book Synopsis Norway’s Sovereign Wealth Fund by : Ole Bjørn Røste

Download or read book Norway’s Sovereign Wealth Fund written by Ole Bjørn Røste and published by Springer Nature. This book was released on 2021-07-19 with total page 267 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book elaborates on how Norway has managed to convert a large fraction of its endowment of hydrocarbons below the seabed of Norwegian waters into financial wealth, invested in the world’s capital markets. Further, it explains how this wealth is managed. Under the current guidelines, only the assessed return on investment may be allotted to public budgets. This ensures that the wealth will benefit both current and future generations. The capital is gathered in the Sovereign Wealth Fund – or State Pension Fund Global (SPF-G) –, which is intended to maximize capital value without exceeding acceptable risks. The book offers new insights into the history and management of the fund, examines its successes,and discusses future challenges. Given its scope, it appeals to scholars of economics, finance and political science, and to anyone interested in the sustainable investment of natural resource-based revenues.

The Effect of Treaties on Foreign Direct Investment

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Publisher : Oxford University Press
ISBN 13 : 0199745188
Total Pages : 800 pages
Book Rating : 4.1/5 (997 download)

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Book Synopsis The Effect of Treaties on Foreign Direct Investment by : Karl P Sauvant

Download or read book The Effect of Treaties on Foreign Direct Investment written by Karl P Sauvant and published by Oxford University Press. This book was released on 2009-03-27 with total page 800 pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.

Taxation of Foreign Investment in U.S. Real Estate

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Author :
Publisher :
ISBN 13 :
Total Pages : 84 pages
Book Rating : 4.:/5 (319 download)

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Book Synopsis Taxation of Foreign Investment in U.S. Real Estate by : United States. Department of the Treasury

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:

The New Frontiers of Sovereign Investment

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Publisher : Columbia University Press
ISBN 13 : 0231543484
Total Pages : 290 pages
Book Rating : 4.2/5 (315 download)

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Book Synopsis The New Frontiers of Sovereign Investment by : Malan Rietveld

Download or read book The New Frontiers of Sovereign Investment written by Malan Rietveld and published by Columbia University Press. This book was released on 2017-05-16 with total page 290 pages. Available in PDF, EPUB and Kindle. Book excerpt: Sovereign wealth funds (SWFs) can be effective tools for national resources revenue management. These state-owned investments, funded by commodity exports, foreign exchange reserves, or other national assets, are adaptable to the challenges posed by financial shocks and have been successfully employed in an increasing number of countries. The number of SWFs continues to grow, with the largest funds managing trillions of dollars in assets among them. However, given the significant variations among SWFs, it can be difficult to compare funds that differ in size, scope, and mandate. This book provides a sorely needed practical look at how these funds work—and how they should work. The New Frontiers of Sovereign Investment combines the insights and experience of academic economists and practitioners from several funds to survey a diverse financial landscape and establish the challenging topical questions facing a broad range of SWFs today: Should they serve both economic development and financial returns, and how? Will responsible investment enhance long-term returns? How can fiscal rules for SWFs be improved to meet emerging economic challenges? The book considers these questions as they apply to both long-established and newer SWFs. Featuring contributions from sovereign wealth practitioners from Alberta's AIMCo, the Nigerian Sovereign Investment Authority, and the New Zealand Superannuation Fund, as well as analysis by scholars at the forefront of sovereign investment, this volume provides timely and much-needed information on these rapidly evolving institutions.

International Taxation of Banking

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403510951
Total Pages : 448 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis International Taxation of Banking by : John Abrahamson

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 448 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.

Exploring the Nexus Doctrine In International Tax Law

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403533641
Total Pages : 234 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Exploring the Nexus Doctrine In International Tax Law by : Ajit Kumar Singh

Download or read book Exploring the Nexus Doctrine In International Tax Law written by Ajit Kumar Singh and published by Kluwer Law International B.V.. This book was released on 2021-05-14 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.

Essays in International Taxation, 1976

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Author :
Publisher :
ISBN 13 :
Total Pages : 316 pages
Book Rating : 4.3/5 (121 download)

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Book Synopsis Essays in International Taxation, 1976 by : United States. Department of the Treasury

Download or read book Essays in International Taxation, 1976 written by United States. Department of the Treasury and published by . This book was released on 1977 with total page 316 pages. Available in PDF, EPUB and Kindle. Book excerpt: The essays analyse the interactions between tax law and tax policy. The analyses evaluate changes which presuppose the foreign tax credit mechanism, the separate taxation of corporations and their shareholders, and other basic elements in US taxation of foreign income.