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Taxation Of Corporate Debt And Financial Instruments
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Book Synopsis Taxation of Corporate Debt and Financial Instruments by : David Southern
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.
Book Synopsis Tolley's Taxation of Corporate Debt and Financial Instruments by : David Southern
Download or read book Tolley's Taxation of Corporate Debt and Financial Instruments written by David Southern and published by Tolley. This book was released on 1998 with total page 364 pages. Available in PDF, EPUB and Kindle. Book excerpt: This work draws together the taxation issues relating to debt instruments used in corporate finance and investment, and offers a complete guide through the maze of new legislation. It focuses on the practical implications of the Finance Act 1996 and also covers the interaction between taxes, the accounting framework, corporate transactions and planning issues.
Book Synopsis Taxation of Corporate Debt and Derivatives by : Julian Ghosh
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: Offering invaluable tax planning help for the tax specialist, 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
Book Synopsis Introduction to the Taxation of Financial Instruments by : Henry D. Shereff
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 426 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tolley's Taxation of Corporate Debt, Foreign Exchange and Derivative Contracts by : David Southern
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.
Book Synopsis The Tax Elasticity of Corporate Debt by : Ruud A. de Mooij
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.
Book Synopsis Federal Income Taxation of Debt Instruments by : David C. Garlock
Download or read book Federal Income Taxation of Debt Instruments written by David C. Garlock and published by Aspen Publishers. This book was released on 1994 with total page 866 pages. Available in PDF, EPUB and Kindle. Book excerpt: Now in its Fourth Edition, Federal Income Taxation of Debt Instruments is the definitive reference for the many complicated issues involved with debt instruments. This comprehensive, one-volume treatise contams clear interpretations of the basic rules governing original issue discount and imputed interested and detailed coverage of many specialized topics. In addition to complete coverage of the final OID Regulations, the new edition covers every aspect of the current regulations and thoroughly analyzes all related areas, including: Market discount -- Short-term obligations -- Belowmarket and intercompany loans -- Coupon stripping -- Bond premiums -- Variable rate debt instruments -- Contingent payment obligations -- Debt workouts -- Mortgage-backed securities. Complete, current, and concise, this book is the most authoritative step-by-step practice guide available.
Book Synopsis Debt, Taxes and Corporate Restructuring by : John B. Shoven
Download or read book Debt, Taxes and Corporate Restructuring written by John B. Shoven and published by Brookings Institution Press. This book was released on 2012-01-01 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: The boom in corporate restructuring, accompanied by large increases in debt finance, was one of the most important developments in the U.S. economy in the 1980s. Financial and tax specialists analyze how the U.S. tax system-especially in its bias toward debt financing-has affected corporate financial decisions and influenced the recent wave of corporate restructuring. The authors evaluate the hypothesis that the rise in the cost of capital during the 1980s helped stimulate the surge in corporate takeovers. They analyze the effect that changes in tax laws and in the volume of government debt have had on corporate financial decisions. The authors examine how recent financial innovations have blurred the distinction between debt and equity finance.
Book Synopsis Hybrid Financial Instruments in International Tax Law by : Jakob Bundgaard
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.
Book Synopsis Effects of Taxation by : Dan Throop Smith
Download or read book Effects of Taxation written by Dan Throop Smith and published by . This book was released on 1952 with total page 328 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tax Reform and the Tax Treatment of Debt and Equity by : United States. Congress. House. Committee on Ways and Means
Download or read book Tax Reform and the Tax Treatment of Debt and Equity written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 2013 with total page 364 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of Financial Products, 2e by : Dearborn Financial Publishing
Download or read book Taxation of Financial Products, 2e written by Dearborn Financial Publishing and published by Kaplan Publishing. This book was released on 2002-04 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Taxation of Financial Products is designed for all financial services professionals.It explains the basics of selected financial products and their income tax treatment.Chapters focus on federal income tax basics, mutual funds, annuities, stocks, bonds, life insurance and qualified plans.The information provided is comprehensive and up to date with current tax laws and figures, as well as planning strategies."Taxation of Financial Products is written in plain English, and provides the financial services professional with the proper information needed to help meet clients' financial objectives. Material has been updated to reflect the changes made by the new distribution rules and the Tax Act of 2001, including updates to rules governing qualified plans, catch up contributions and simplification of required minimum distribution rules, and facts, figures, illustrations and examples have been updated. If you are taking this course for CE, the CE exam will automatically be added to your basket when selecting CE credit.Certain states require that a proctor/monitor supervise the exam taking process.
Book Synopsis Taxation of Loan Relationships and Derivative Contracts by : David Southern
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.
Book Synopsis Investment Taxation by : Arlene Mary Hibschweiler
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
Book Synopsis Ghosh, Johnson and Miller on the Taxation of Corporate Debt and Derivatives by : Julian Ghosh
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:
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)
Book Synopsis Hybrid Financial Instruments, Double Non-Taxation and Linking Rules by : Félix Daniel Martínez Laguna
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.
Book Synopsis Federal Income Tax Aspects of Corporate Financial Structures by : United States. Congress. House. Committee on Ways and Means
Download or read book Federal Income Tax Aspects of Corporate Financial Structures written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1989 with total page 136 pages. Available in PDF, EPUB and Kindle. Book excerpt:
