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Author: Lawrence Lokken
Publisher:
ISBN:
Category :
Languages : en
Pages : 30
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Book Description
Author: Antti Laukkanen
Publisher: IBFD
ISBN: 9087220227
Category : Bonds
Languages : en
Pages : 487
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Book Description
This dissertation aims to provide a comprehensive overview of the taxation of investment derivatives and the relationship between the derivatives and the accrual and realization methods. Investment derivatives, such as convertible bonds, include an initial investment and a derivative (an option) to buy or sell or to participate in the value movements of some underlying property. The principal focus of this study is on three universal tax issues, namely valuation, timing and the taxation of unrealized gains. As a common principle, interest income and capital gains are treated more similarly in corporate taxation than in individual taxation. Moreover, the taxation of financial instruments is currently in a turn-around phase in several countries, not least because of the implementation of the IFRS rules in accounting and the related fair value principle. The obligation to use fair values in accounting apparently motivates tax legislators to strive to use the same principles in taxation as well. The comparative method plays a major role in this study by examining the tax legislations and the tax practices of different countries. An in-depth analysis of the similarities and differences of tax laws and practices in the United States, the United Kingdom, Germany, Finland and Sweden is provided. This is of particular interest as the underlying components, single and often specified financial derivatives, are basically identical. While this study does not deal with individual tax treaties or bilateral transactions, the OECD Model is scrutinized in order to highlight the underlying principles of the given recommendations, especially with respect to interest income and capital gains. Due to the increasing importance of IFRS rules in accounting, the study is not limited to tax law, but also looks at issues from the perspective of finance, accounting and economics.
Author: United States. Congress. Senate. Committee on Finance
Publisher:
ISBN:
Category : Financial instruments
Languages : en
Pages : 548
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Book Description
Author: Lawrence Lokken
Publisher:
ISBN:
Category :
Languages : en
Pages : 30
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Book Description
Author: Frank J. Fabozzi, CFA
Publisher: John Wiley & Sons
ISBN: 9781883249557
Category : Business & Economics
Languages : en
Pages : 320
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Book Description
The Use of Derivatives in Tax Planning provides insightful and in-depth coverage of timely issues including: tax treatments of notional principal contracts, taxation of credit derivatives, derivative tax planning applications for fixed-income instruments, using derivatives to shift income, enhancing after-tax returns, working with the straddle rules of tax code sections 1092 and 263(g), derivatives in the charitable world, using OTC equity derivatives for high-net-worth individuals, corporate applications of derivatives, synthetic exchangeables and convertibles, and structures and selected tax issues.
Author: T. Rumble
Publisher: Springer
ISBN: 023051314X
Category : Business & Economics
Languages : en
Pages : 265
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Book Description
The taxation of equity derivatives and structured products is analyzed in detail by Tony Rumble and his contributors, Mohammed Amin and Ed Kleinbard. The book covers the financial and tax technical analysis of issues relating to equity derivatives and structured products. Part 1 examines the derivatives building blocks and financial market/corporate finance drivers of the equity derivatives and financial products market, and includes case studies of typical and landmark transactions. Part 2 looks at the tax technical rules in each of the target countries - the US, UK and Australia - and examines the specific products highlighted in the first part of the book. Case studies of significant transactions are included where necessary.
Author: Mark J. P. Anson
Publisher: John Wiley & Sons
ISBN: 9781883249694
Category : Business & Economics
Languages : en
Pages : 202
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Book Description
Derivatives and credit derivatives have emerged as significant areas of interest in portfolio planning and risk management. In this book, Mark Anson examines the accounting and taxation implications of these instruments, including the new accounting rules for derivative instruments promulgated by the financial Accounting Standards in the United States, the Accounting Standards Board in Great Britain, and the International Accounting Standards Committee. Regulatory requirements for disclosing derivatives and tax considerations for derivative instruments are discussed (including TRA-97.) Additionally, the book reviews the regulatory accounting deadlines introduced by the Securities and Exchange Commission and the Commodity Futures Trading Commission.
Author: Raymond Looze
Publisher:
ISBN:
Category : Derivative securities
Languages : en
Pages : 64
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Book Description
This book deals with the tax treatment of derivative financial instruments in the Netherlands and the USA. The main characteristics of option-based and future based contracts including swaps, are described.
Author: Jeremy Bradburne
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 288
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Book Description
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.
Author: Oktavia Weidmann
Publisher: Kluwer Law International B.V.
ISBN: 9041159835
Category : Law
Languages : en
Pages : 439
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Book Description
The exploding use of derivatives in the last two decades has created a major challenge for tax authorities, who had to develop appropriate derivatives taxation rules that strike a balance between allowing capital markets to function effectively by removing artificial tax barriers and at the same time protecting their countries' tax base from tax avoidance schemes that utilise these instruments. Derivatives exist in a vast variety and complexity and new forms or combinations of existing forms appear ad hoc as new risk categories emerge and companies seek to invest in or hedge these risks. This very thorough book discusses and analyses taxation issues posed by derivatives used in domestic as well as in cross-border transactions. In great detail the author presents approaches that can be adopted by tax legislators to solve these problems, clarifying her solutions with specific reference to components of the two most important domestic tax systems in relation to derivatives in Europe, those of the United Kingdom and Germany. Examples of derivatives transactions and arbitrage schemes greatly elucidate the nature of derivatives and how they can be effectively taxed. The following aspects of the subject and more are covered: – basic economic concepts in the context of derivatives such as replication, put-call-parity, hedging and leverage; - designing a suitable definition of derivatives in domestic tax law; - achieving coherence in domestic tax rules by applying a 'special regime approach' versus an 'integrative approach' and the distinction of income and capital, equity and debt; - alignment of accounting standards and taxation rules and the application of fair value accounting for tax purposes; - how to tax hedged positions and post-tax hedging schemes; - taxation of structured financial products and hybrid instruments with focus on bifurcation and integration approaches and the recent BEPS discussion drafts on hybrid mismatch arrangements; - refining the 'beneficial ownership' – concept in domestic law and in tax treaties and an analysis of recent case law; - withholding taxes in the context of domestic and cross-border dividend tax arbitrage schemes; and - tackling derivatives tax arbitrage effectively in anti-avoidance legislation. By providing an in-depth analysis of corporate taxation issues that arise in domestic as well as in cross-border derivatives transactions, this book is not only timely but of lasting value in the day-to-day work of tax lawyers and tax professionals in companies, banks and funds, and is sure to be of interest to government officials, academics and researchers involved with financial instruments taxation.
Author: Joshua Banafsheha
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 0
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Book Description
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.
