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Author: Ross K. McGill
Publisher: Springer Nature
ISBN: 3031327853
Category : Business & Economics
Languages : en
Pages : 405
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Book Description
This book provides a clear and concise explanation of withholding tax and how to leverage best practice to generate improved investment performance. It gives practical guidance to financial service firms and investors to help them understand the issues involved, trends and practicalities of maximizing returns on investment. Most of the $200 billion of withholding tax lost by investors annually is due to lack of awareness and not asking the right questions of their brokers and custodian banks. Financial institutions are also increasingly being held to a higher standard by investors for provision of withholding tax services because of the impact it can have on portfolio performance. This book seeks to raise awareness of the issues and provide more detail about how the system works and what challenges and changes readers should expect in the future.
Author: Ross K. McGill
Publisher: Springer Nature
ISBN: 3031327853
Category : Business & Economics
Languages : en
Pages : 405
Get Book Here
Book Description
This book provides a clear and concise explanation of withholding tax and how to leverage best practice to generate improved investment performance. It gives practical guidance to financial service firms and investors to help them understand the issues involved, trends and practicalities of maximizing returns on investment. Most of the $200 billion of withholding tax lost by investors annually is due to lack of awareness and not asking the right questions of their brokers and custodian banks. Financial institutions are also increasingly being held to a higher standard by investors for provision of withholding tax services because of the impact it can have on portfolio performance. This book seeks to raise awareness of the issues and provide more detail about how the system works and what challenges and changes readers should expect in the future.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264172882
Category :
Languages : en
Pages : 172
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Book Description
This book analyses the taxation of cross-border portfolio investments by means of collective investment institutions. Possible tax distortions specific to the area of collective investment institutions are identified for a representative group of OECD countries.
Author: Andreas Oestreicher
Publisher: Springer Science & Business Media
ISBN: 3319004492
Category : Law
Languages : en
Pages : 170
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Book Description
The Fund Reporting Cloud® has made tax reporting less complex, but comparing the effective tax treatment of investment funds and their investors in an international environment is still an ambitious task. Against this background, this study examines the tax consequences at fund, asset, and investor level. In geographical terms our comparison covers eleven European countries, the USA, and Japan. Our analysis of the relevant tax provisions, which is of a primarily qualitative nature, is complemented by a quantitative comparison of the tax burden for a model investor investing assets nationally in the form of a collective investment. It will be of interest both for investors seeking tax advantages and for governments to check whether there is a need for tax reforms. It also ties in perfectly with the current evaluations at OECD level in the context of TRACE.
Author: Ross McGill
Publisher:
ISBN: 9781843740506
Category : Income tax
Languages : en
Pages : 152
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Book Description
'International Withholding Tax' explains that whether you are a private investor or an institutional investor, your investments are potentially subject to withholding tax.
Author: Mindy Herzfeld
Publisher: Kluwer Law International B.V.
ISBN: 9403528915
Category : Law
Languages : en
Pages : 435
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Book Description
Structuring Cross-Border Transactions: U.S. Tax Considerations The U.S. international tax provisions that impact cross-border transactions are far-reaching. In recent years, the rules have become more complex, less systematic, and more difficult to make sense of. In this helpful book, a well-known author and practitioner demystifies many of the structuring questions implicated in inbound and outbound cross-border investments, acquisitions, and joint ventures, exposing traps and planning opportunities and showing how the rules really operate in specific fact patterns. All key aspects of structuring a cross-border transaction are analyzed, including: anti-deferral regimes (subpart F and global intangible low-taxed income (GILTI)); how check-the-box (CTB) regulations can maximize tax benefits and minimize tax inefficiencies; how the indirect foreign tax credit provides opportunities for tax beneficial planning; U.S. tax-free reorganization rules as they apply in the cross-border area; U.S. anti-inversion rules that affect cross-border deals; effect of anti-hybrid rules; concerns of particular classes of investors that will influence the form of a transaction; and typical points of friction between buyers and sellers in the cross-border context. Detailed examples, with financial metrics included, help guide decision making at every step and assist in the understanding of key drivers materially impacting results. Treaty considerations and implications are discussed throughout. This book fills a big gap in the tax literature by providing a guide for practitioners from any country who need to understand the U.S. tax consequences of a particular transaction. Its focus on how U.S. tax law affects the ways in which transactions are put together in the real world, and its in-depth analysis of how U.S. tax provisions interrelate and interact with foreign tax rules will prove of immeasurable value to corporate lawyers, finance professionals, and others active in cross-border mergers and acquisitions. It will become an indispensable reference tool for transactional tax practitioners.
Author:
Publisher: Org. for Economic Cooperation & Development
ISBN:
Category : Business & Economics
Languages : en
Pages : 184
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Book Description
The past decade has witnessed a significant increase in cross-border capital flows and a pronounced shift in their composition towards portfolio investment, with much of the capital under management by mutual funds or "collective investment institution
Author: Amar Mehta
Publisher: IBFD
ISBN: 9076078718
Category : Corporations, Foreign
Languages : en
Pages : 307
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Book Description
This book discusses the practical issues faced by the banks, financial institutions, companies engaging in leasing as a form of asset financing, and their tax advisers. The book elaborately deals with the divergent tax treatment in the five most important leasing jurisdictions (ie, US, Japan, Germany, UK and Netherlands) in respect of transaction characterization, depreciation, income-recognition and anti-avoidance rules, as well as divergence in the relevant bilateral tax treaty provisions. Further, the book investigates how the parties to a cross-border leasing transaction may obtain tax advantages due to such divergent tax treatments, and whether and to what extent the general or specific anti-avoidance rules in the jurisdictions may neutralize the tax arbitrage opportunities. Finally, it examines how the framework of the EC Treaty may be relevant for cross-border leasing transactions between the EC Member States.
Author: Erwin Nijkeuter
Publisher: Kluwer Law International B.V.
ISBN: 9041140859
Category : Law
Languages : en
Pages : 168
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Book Description
This book is the first in-depth study to analyze the circumstances in which the freedom of establishment or free movement of capital may apply to the cross-border distribution of dividends. It covers both the positive integration set forth by the European Commission and the Member States and the negative integration developed by the European Court of Justice. The author discusses such elements of these integration measures as the following: economic double taxation (two different subjects pay tax on the same profit); juridical double taxation (two different states tax one and the same person for the same income); exemption, credit, and other techniques adopted by States to avoid double taxation; division of taxing rights between two States with respect to dividend income; prevention of juridical double taxation by bilateral tax conventions; Member States’ mitigation of economic double taxation; double exemption as an unplanned outcome of double taxation prevention measures; and order of precedence between freedom of establishment and free movement of capital. The analysis treats relevant provisions the OECD Model Tax Convention in detail, as this model is widely used by national tax authorities in connection with international taxation of dividends. It also examines pertinent initiatives launched by the European Commission up to and including its consultation paper of January 28, 2011. In addition to its scrutiny of the disparities in cross-border dividend taxation within the European Union, this book stands out for its detailed coverage of the progress made in resolving these challenging taxation issues. It is sure to be welcomed by investors, corporate counsel, and national revenue authorities.
Author: John Whalley
Publisher:
ISBN:
Category : Capital movements
Languages : en
Pages : 44
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Book Description
I discuss the tax treatment of transborder capital income, focussing on prevailing arrangements rather than de novo design of optimal tax arrangements. These comprise unilateral reliefs from double taxation under credit or exemption systems, and treaty reliefs (largely following the OECD model treaty) which jointly lower withholding tax rates on interest, dividends, and royalties in both host and source countries. I suggest that these arrangements involve both seemingly non-strategic unilateral actions and cooperative arrangements which are difficult to reconcile both with tax competition literature and with national interest. I pose four puzzles in this regard. The first is that from a national welfare point of view, the unilateral reliefs in use seem inferior to no relief since with competitive markets investors equate the private return on investments at home and abroad, while tax revenues largely accrue to the foreign government. Private returns are equated, but national returns are not. The second is that tax treaties only have lump sum effects between national governments if the more common credit arrangements of unilateral reliefs apply and if tax rates are similar in host and source countries (approximately the OECD situation). This raises the issue of why governments negotiate them. The third is the sharp contrast to international treaty arrangements for goods flows under the WTO; and the fourth is the absence of side payments in tax treaties. The picture emerging is that making sense of present arrangements from a national welfare point of view and in terms of efficient instrument design seems difficult. The gap relative to optimal tax considerations also seems large.
Author: Sebastian Beer
Publisher: International Monetary Fund
ISBN: 1513519972
Category : Business & Economics
Languages : en
Pages : 32
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Book Description
We analyze the impact of exchange of information in tax matters in reducing international tax evasion between 1995 and 2018. Based on bilateral deposit data for 39 reporting countries and more than 200 counterparty jurisdictions, we find that recent automatic exchange of information frameworks reduced foreign-owned deposits in offshore jurisdictions by an average of 25 percent. This effect is statistically significant and, as expected, much larger than the effect of information exchange upon request, which is not significant. Furthermore, to test the sensitivity of our findings, we estimate countries’ offshore status and the impact of information exchange simultaneously using a finite mixture model. The results confirm that automatic (and not upon request) exchange of information impacts cross-border deposits in offshore jurisdictions, which are characterized by low income tax rates and strong financial secrecy.
