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Transfer Pricing Aspects Of Real Estate Financing
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Book Synopsis Transfer Pricing Aspects of Real Estate Financing by : M. Bonekamp
Download or read book Transfer Pricing Aspects of Real Estate Financing written by M. Bonekamp and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: There has been a lot of interest in the transfer pricing of intercompany loans recently, especially following the new guidance released by the OECD on financial transactions in February 2020. However, there are no specific details on the financing of real estate in this new guidance, although in practice the financing of real estate has some unique characteristics. In this article, the authors highlight several aspects that are specific to real estate financing and their impact on transfer pricing. The focus is mainly on investments by multinational enterprises in commercial real estate (CRE), i.e. income-producing property used solely for business purposes, rather than residential property. Examples of CRE include retail malls, shopping centres, office buildings and hotels.
Book Synopsis Transfer Pricing and Intra-group Financing by : Anuschka Bakker
Download or read book Transfer Pricing and Intra-group Financing written by Anuschka Bakker and published by IBFD. This book was released on 2012 with total page 593 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.
Book Synopsis Modern Real Estate Finance and Land Transfer by : Steven Bender
Download or read book Modern Real Estate Finance and Land Transfer written by Steven Bender and published by . This book was released on 2008 with total page 1108 pages. Available in PDF, EPUB and Kindle. Book excerpt: This challenging yet accessible casebook examines the legal, business, and tax issues of real estate financing through a transactional and interdisciplinary approach. Written by scholar-practitioners, Modern Real Estate Finance and Land Transfer: A Transactional Approach, Fourth Edition, uses real-world examples to illustrate the lawyer’s role in both residential and commercial real estate transactions. Among the attributes that make this class-tested casebook a success: a sophisticated, yet teachable style thorough explanations of the increasingly complex legal, business, and tax issues surrounding real estate transactions the transactional and interdisciplinary approach demonstrates the general rules of law that govern a given real estate transaction, The rules’ underlying rationale or policy, and how (or whether) a rule can be superseded by the mutual consent of each party real-world examples that help foster practical skills required of attorneys in real estate firms and clear explanations that demonstrate rules of law that govern a real estate transaction questions and planning problems that allow students to examine issues in the context of relevant transactions or documents a topical and chronological organization that covers both real estate and real estate finance and follows the lending cycle in modern real estate financing Special features of the Fourth Edition, completely updated to reflect changes in the law, include: bankruptcy reform law changes discussion of the popularization in recent years of “exotic” forms of financing, particularly in residential markets changes in the prepayment area treatment of the so-called mortgage meltdown in 2007 updated and substantially rewritten materials on the economics of real estate investments, selection of the ownership entity, and securitization new title insurance forms consideration of mold—the “new asbestos” an updated Teacher’s Manual Modern Real Estate Finance and Land Transfer: A Transactional Approach, Fourth Edition, Is the perfect casebook for professors who cover the complex financial and tax aspects of real estate law—whether in a basic real estate course and or an advanced seminar.
Book Synopsis Modern Real Estate Finance and Land Transfer by : Steven W. Bender
Download or read book Modern Real Estate Finance and Land Transfer written by Steven W. Bender and published by Aspen Publishing. This book was released on 2018-11-06 with total page 1340 pages. Available in PDF, EPUB and Kindle. Book excerpt: Modern Real Estate Finance and Land Transfer—sophisticated, yet teachable—explains the increasingly complex legal, business, and tax issues surrounding real estate transactions with discussion relevant to both commercial and residential situations. Through a transactional and interdisciplinary approach, students learn the general rules of law, their underlying rationale or policy, and how (or whether) a rule can be superseded by the mutual consent. Real-world examples help foster practical skills required of attorneys in real estate firms, and the text is appropriate for both a basic Real Estate Transactions or Finance course and also advanced seminars. Topical and chronological organization features coverage of both Real Estate Sales and Real Estate Finance and follows the lending cycle in modern financing. Questions and planning problems help students examine issues in the context of relevant transactions and documents for sale, finance, leasing, and development transactions. The authors are scholar-practitioners who skillfully mix practical skills and theory students will need in today’s competitive legal markets. Key Features: sophisticated, yet teachable—thoroughly explains complex legal, business, and tax issues in real estate transactions transactional, interdisciplinary approach teaches the general rules of law shows underlying rationale or policy explores how (or whether) a rule can be superseded by mutual consent real-world examples and accessible explanations topical and chronological organization coverage of both Real Estate Sales and Real Estate Finance follows lending cycle in modern real estate financing appropriate for both basic Real Estate Transactions or Finance course and advanced seminars relevant questions and planning problems written by scholar-practitioners who blend practical skills with theory suited to both commercial and residential real estate transactions Thoroughly updated, the revised Sixth Edition presents changes in the law since 2013, including: case law responses to the recent mortgage crisis in residential real estate including lender refusals to fund committed construction loans new case law involving nonrecourse carve-outs a new section and cases on recourse against and protection of the guarantor, and ethical issues in guarantor representation new developments in bankruptcy law involving real estate transactions
Book Synopsis Transfer Pricing Aspects of Intra-Group Financing by : Raffaele Petruzzi
Download or read book Transfer Pricing Aspects of Intra-Group Financing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2013-10-20 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.
Book Synopsis Tax Aspects of Real Estate Investments by :
Download or read book Tax Aspects of Real Estate Investments written by and published by . This book was released on 1988 with total page 618 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transfer Pricing and Financing by : Raffaele Petruzzi
Download or read book Transfer Pricing and Financing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 261 pages. Available in PDF, EPUB and Kindle. Book excerpt: In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties. Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions: loans; financial guarantees; cash pooling; hybrid financing; factoring; captive insurance; and asset management. Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law. Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.
Book Synopsis Applying the Arm's Length Principle to Intra-group Financial Transactions by : Robert Danon
Download or read book Applying the Arm's Length Principle to Intra-group Financial Transactions written by Robert Danon and published by Kluwer Law International B.V.. This book was released on 2023-08-29 with total page 1053 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
Book Synopsis U.S. Transfer Pricing Sourcebook by : Amanda Johnson
Download or read book U.S. Transfer Pricing Sourcebook written by Amanda Johnson and published by WorldTrade Executive, Inc.. This book was released on 2005-03 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: U.S. TRANSFER PRICING SOURCEBOOK is a single-volume report designed to advise international finance professionals on the cutting edge tools and techniques being developed and applied by leading consultants. This sourcebook provides strategies on Intercompany Sales, Intercompany Service transactions, Cross-Border licensing, and Cost Sharing agreements.
Book Synopsis Land Transfer and Finance by : Curtis J. Berger
Download or read book Land Transfer and Finance written by Curtis J. Berger and published by Wolters Kluwer Law & Business. This book was released on 2007 with total page 1090 pages. Available in PDF, EPUB and Kindle. Book excerpt: Be sure to examine this thorough revision before you teach your next course in real estate transactions and financing. Whether you focus on the taxation and financing aspects of a transaction or the contractual and title areas, you will find that
Book Synopsis Practical Guide to U.S. Transfer Pricing by : Robert T. Cole
Download or read book Practical Guide to U.S. Transfer Pricing written by Robert T. Cole and published by Aspen Publishers. This book was released on 1999 with total page 1302 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.
Book Synopsis Real Estate Due Diligence by : Tobias Just
Download or read book Real Estate Due Diligence written by Tobias Just and published by Springer. This book was released on 2017-09-27 with total page 219 pages. Available in PDF, EPUB and Kindle. Book excerpt: Due diligence is the bedrock of real estate deals, regardless of the volume of transaction. This book presents a comprehensive guide to understanding and implementing due diligence and making an accurate assessment of the risks. While this process has become a “no-brainer” for investment professionals, the market standard on this essential topic has not yet been laid out in a comprehensive form that covers all the major aspects of real estate due diligence: legal, tax, financial and technical issues. This book fulfils that need, and gives it a form that can be used for German, European, or even international transactions. Written in a reader-friendly fashion, the easily navigable chapters are organized into the four due diligence dimensions, with ample examples and key takeaways. Be they real estate investors, or a management students specializing in the asset class, this book is a core resource for anyone wanting to get to grips with due diligence.
Book Synopsis Tax Aspects of Real Estate Transactions by : Martin Atlas
Download or read book Tax Aspects of Real Estate Transactions written by Martin Atlas and published by . This book was released on 1966 with total page 394 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transfer Pricing and Value Creation by : Raffaele Petruzzi
Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi and published by Linde Verlag GmbH. This book was released on 2019-09-02 with total page 572 pages. Available in PDF, EPUB and Kindle. Book excerpt: Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Book Synopsis Tax and Financing Aspects of Real Estate Investment by : Laventhol & Horwath
Download or read book Tax and Financing Aspects of Real Estate Investment written by Laventhol & Horwath and published by Don Mills, Ont. : CCH Canadian. This book was released on 1985 with total page 201 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Real Estate Financing by : Patrick J. Rohan
Download or read book Real Estate Financing written by Patrick J. Rohan and published by . This book was released on 1991 with total page 946 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Real Estate Transactions by : Gerald Korngold
Download or read book Real Estate Transactions written by Gerald Korngold and published by . This book was released on 2002 with total page 1096 pages. Available in PDF, EPUB and Kindle. Book excerpt: Updated and expanded, Real Estate Transactions: Cases and Materials on Land Transfer, Development and Finance provides an overview of this growing area of law. Highlights of the new edition include a new section on the globalization of American real estate transactions and finance; new cases on the basic elements of the real estate transaction, including brokers, contract conditions, contract remedies, escrow arrangements, legal descriptions, the recording system, mortgage refinancing, and installment sales agreements; increased coverage of the secondary market for mortgages and Federal National Mortgage Association and Freddie Mac transactions; and expanded coverage of shopping center development, including percentage rent and subordination agreements.
