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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.
Book Synopsis Taxation of New Financial Instruments by : Organisation for Economic Co-operation and Development
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.
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 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.
Book Synopsis The Taxation of Global Trading of Financial Instruments by : OECD
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.
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 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 Tax Reform and the Tax Treatment of Financial Products by : United States. Congress. Senate. Committee on Finance
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:
Book Synopsis Taxation of New Financial Instruments by : Antonio H. Figueroa
Download or read book Taxation of New Financial Instruments written by Antonio H. Figueroa and published by . This book was released on 2001 with total page 22 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.
Book Synopsis Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context by : Sven-Eric Bärsch
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.
Document released for public comment. Includes transfer pricing.
Book Synopsis The Taxation of Global Trading of Financial Instruments by : Organisation for Economic Co-operation and Development. Special Sessions on Innovative Financial Transactions
Download or read book The Taxation of Global Trading of Financial Instruments written by Organisation for Economic Co-operation and Development. Special Sessions on Innovative Financial Transactions and published by Organisation for Economic Co-operation and Development. This book was released on 1998-03-03 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt: Document released for public comment. Includes transfer pricing.
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.
Book Synopsis Butterworths International Taxation of Financial Instruments and Transactions by : Jeremy Bradburne
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.