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Author : Henry D. Shereff
Publisher :
ISBN 13 :
Total Pages : 424 pages
Book Rating : 4.:/5 (43 download)
Download or read book Introduction to the Taxation of Financial Instruments written by Henry D. Shereff and published by . This book was released on 1990 with total page 424 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Organisation for Economic Co-operation and Development
Publisher : OECD
ISBN 13 :
Total Pages : 128 pages
Book Rating : 4.F/5 ( download)
Download or read book Taxation of New Financial Instruments written by Organisation for Economic Co-operation and Development and published by OECD. This book was released on 1994 with total page 128 pages. Available in PDF, EPUB and Kindle. Book excerpt: Presents the results of an analysis of the application of domestic laws and tax treaties to four particular types of instruments: interest rate swaps, financial futures, options to by shares, and bonds issued at a deep discount. Explores the possibility of arriving at consistent treatment of these instruments to provide greater certainty for both tax administrators and the financial markets.
Author : Arlene Mary Hibschweiler
Publisher : McGraw Hill Professional
ISBN 13 : 9780071396967
Total Pages : 478 pages
Book Rating : 4.3/5 (969 download)
Download or read book Investment Taxation written by Arlene Mary Hibschweiler and published by McGraw Hill Professional. This book was released on 2003 with total page 478 pages. Available in PDF, EPUB and Kindle. Book excerpt: Publisher Description
Author : Jakob Bundgaard
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041183183
Total Pages : 498 pages
Book Rating : 4.0/5 (411 download)
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.
Author : United States. Congress. Senate. Committee on Finance
Publisher :
ISBN 13 :
Total Pages : 548 pages
Book Rating : 4.:/5 (319 download)
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:
Author : Sven-Eric Bärsch
Publisher : Springer Science & Business Media
ISBN 13 : 3642324576
Total Pages : 406 pages
Book Rating : 4.6/5 (423 download)
Download or read book Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context written by Sven-Eric Bärsch and published by Springer Science & Business Media. This book was released on 2012-12-13 with total page 406 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite the enormous diversity and complexity of financial instruments, the current taxation of hybrid financial instruments and the remuneration derived therefrom are characterized by a neat division into dividend-generating equity and interest-generating debt as well as by a coexistence of source- and residence-based taxation. This book provides a comparative analysis of the classification of hybrid financial instruments in the national tax rules currently applied by Australia, Germany, Italy and the Netherlands as well as in the relevant tax treaties and EU Directives. Moreover, based on selected hybrid financial instruments, mismatches in these tax classifications, which lead to tax planning opportunities and risks and thus are in conflict with the single tax principle, are identified. To address these issues, the author provides reform options that are in line with the dichotomous debt-equity framework, as he/she suggests the coordination of either tax classifications or tax treatments.
Author : G. M. M. Michielse
Publisher : Springer
ISBN 13 :
Total Pages : 376 pages
Book Rating : 4.F/5 ( download)
Download or read book Tax Treatment of Financial Instruments:A Survey to France, Germany, The Netherlands and the United Kingdom written by G. M. M. Michielse and published by Springer. This book was released on 1996-04-17 with total page 376 pages. Available in PDF, EPUB and Kindle. Book excerpt: General overview of the tax treatments of various financial instruments in four important EC Member States: France, Germany, the Netherlands and the United Kingdom, showing the most important tax differences and outlining the points on which EC harmonization is the most imperative, but also the most difficult to realize.
Author : Great Britain. Department of Inland Revenue
Publisher :
ISBN 13 :
Total Pages : 55 pages
Book Rating : 4.:/5 (1 download)
Download or read book Financial Instruments written by Great Britain. Department of Inland Revenue and published by . This book was released on 1991 with total page 55 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Timothy Edgar
Publisher : Canadian Tax Foundation = L'Association canadienne d'études fiscales
ISBN 13 : 9780888081582
Total Pages : 645 pages
Book Rating : 4.0/5 (815 download)
Download or read book The Income Tax Treatment of Financial Instruments written by Timothy Edgar and published by Canadian Tax Foundation = L'Association canadienne d'études fiscales. This book was released on 2000 with total page 645 pages. Available in PDF, EPUB and Kindle. Book excerpt: Examines the theoretical and practical aspects of the treatment of financial instruments under a realisation-based income tax. Argues that, within such a context, a system of expected-return taxation in preferable. The argument is developed through a review of the academic literature and selected legislative regimes.
Author : Junggun Oh
Publisher :
ISBN 13 :
Total Pages : 34 pages
Book Rating : 4.:/5 (318 download)
Download or read book Tax Treatment of Financial Instruments in the SEACEN Countries written by Junggun Oh and published by . This book was released on 1992 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Mr.Howell H. Zee
Publisher : International Monetary Fund
ISBN 13 : 1589063163
Total Pages : 100 pages
Book Rating : 4.5/5 (89 download)
Download or read book Taxing the Financial Sector written by Mr.Howell H. Zee and published by International Monetary Fund. This book was released on 2004-04-16 with total page 100 pages. Available in PDF, EPUB and Kindle. Book excerpt: One of the most complex issues in tax policy today is the treatment of the institutions, products, and services that make up the financial sector. It can be harder to ascertain income, expenses, and profits for financial firms than for firms selling goods and services, and it is easier for individuals and firms to manipulate financial transactions so as to exploit tax loopholes. This volume explores the challenges faced by tax policymakers and identifies modern best practices in several areas: banks, insurance companies, securities companies, investment funds, pension funds, and derivatives.
Author : Antti Laukkanen
Publisher : IBFD
ISBN 13 : 9087220227
Total Pages : 487 pages
Book Rating : 4.0/5 (872 download)
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.
Author : Mr.John R. King
Publisher : International Monetary Fund
ISBN 13 : 1451846517
Total Pages : 32 pages
Book Rating : 4.4/5 (518 download)
Download or read book The Taxation of Financial Assets written by Mr.John R. King and published by International Monetary Fund. This book was released on 1995-05-01 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: Taxes affect the degree and efficiency of financial intermediation in many different ways. This paper summarizes the main tax provisions in OECD countries that affect the overall “tax wedge” between pre-tax returns on investments, and the post-tax yield on the savings that finance them. This tax wedge is shown to vary widely, in individual countries, according to the different ways in which savings are channeled through financial markets. The paper then discusses alternative criteria for assessing tax regimes for financial assets, and summarizes recent trends in OECD countries.
Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264162496
Total Pages : 71 pages
Book Rating : 4.2/5 (641 download)
Download or read book The Taxation of Global Trading of Financial Instruments written by OECD and published by OECD Publishing. This book was released on 1998-03-09 with total page 71 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication thoroughly reviews the factual background to global trading, analyses the challenges posed to traditional taxation methods and discusses a range of policy options to tackle the problems.
Author :
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (763 download)
Download or read book Tax Treatment of Financial Instruments written by and published by . This book was released on 1996 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Jeremy Bradburne
Publisher :
ISBN 13 :
Total Pages : 288 pages
Book Rating : 4.F/5 ( download)
Download or read book Butterworths International Taxation of Financial Instruments and Transactions written by Jeremy Bradburne and published by . This book was released on 1994 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: Thorough treatment of international taxation aspects of financial instruments. The treatment covers general US tax principles, equities, debt securities and derivatives and other financial instruments.
Author : Félix Daniel Martínez Laguna
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403510846
Total Pages : 685 pages
Book Rating : 4.4/5 (35 download)
Download or read book Hybrid Financial Instruments, Double Non-Taxation and Linking Rules written by Félix Daniel Martínez Laguna and published by Kluwer Law International B.V.. This book was released on 2019-06-12 with total page 685 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.
