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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 424 pages. Available in PDF, EPUB and Kindle. Book excerpt:
This book provides the reader with an introduction to the taxation of financial instruments. Beginning with foundational tax and finance concepts, it navigates through common financial instruments and transactions, detailing their tax implications. The instruments covered in this book range from equity and debt to derivatives (including options, forwards, futures, and swaps), while the transactions discussed include short sales, wash sales, tax straddles, and constructive sales. Each chapter begins with a clear explanation of the relevant instrument or transaction before delving into the tax treatment. Suitable for readers curious about financial instruments, tax law, or both, this book offers a useful guide for understanding a complex area of tax law.
Book Synopsis An Introduction to the Taxation of Financial Instruments by : Joshua Banafsheha
Download or read book An Introduction to the Taxation of Financial Instruments written by Joshua Banafsheha and published by . This book was released on 2024-06-02 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides the reader with an introduction to the taxation of financial instruments. Beginning with foundational tax and finance concepts, it navigates through common financial instruments and transactions, detailing their tax implications. The instruments covered in this book range from equity and debt to derivatives (including options, forwards, futures, and swaps), while the transactions discussed include short sales, wash sales, tax straddles, and constructive sales. Each chapter begins with a clear explanation of the relevant instrument or transaction before delving into the tax treatment. Suitable for readers curious about financial instruments, tax law, or both, this book offers a useful guide for understanding a complex area of tax law.
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
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 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 Taxation and Accounting for Financial Instruments by : Simon Peerless
Download or read book Taxation and Accounting for Financial Instruments written by Simon Peerless and published by . This book was released on 1991 with total page 202 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 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 עדות לפעילות נוירוטרופית של נוגדי דיכאון מקבוצת מעכבי קליטת סרוטונין ואנלוגים שלהם בשורות תאים ממקור מוחי ובמודל של זקנה בעכברים by :
Download or read book עדות לפעילות נוירוטרופית של נוגדי דיכאון מקבוצת מעכבי קליטת סרוטונין ואנלוגים שלהם בשורות תאים ממקור מוחי ובמודל של זקנה בעכברים written by and published by . This book was released on 2009 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation and Accounting for Financial Instruments by : Ian Watson
Download or read book Taxation and Accounting for Financial Instruments written by Ian Watson and published by . This book was released on 1988-11 with total page 147 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Virtually every large U.S. or foreign-based multinational company has a treasury department that is responsible for raising capital, managing risk, and handling investment activities. This work is designed and written to help in-house and external tax advisors understand the tax law that applies to common treasury functions including the taxation of financial products and transactions. The tax law in the financial instruments and transactions area changes frequently. In addition, with the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, there is a possibility that extremely significant changes may be made to the manner in which common risk management and investment transactions are taxed.
Book Synopsis Practical Guide to the Taxation of Financial Transactions by : Michael J. Feder
Download or read book Practical Guide to the Taxation of Financial Transactions written by Michael J. Feder and published by CCH Incorporated. This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Virtually every large U.S. or foreign-based multinational company has a treasury department that is responsible for raising capital, managing risk, and handling investment activities. This work is designed and written to help in-house and external tax advisors understand the tax law that applies to common treasury functions including the taxation of financial products and transactions. The tax law in the financial instruments and transactions area changes frequently. In addition, with the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act, there is a possibility that extremely significant changes may be made to the manner in which common risk management and investment transactions are taxed.
Book Synopsis Taxation of Derivatives and New Financial Instruments by : Lawrence Lokken
Download or read book Taxation of Derivatives and New Financial Instruments written by Lawrence Lokken and published by . This book was released on 1995 with total page 30 pages. Available in PDF, EPUB and Kindle. Book excerpt: