US Tax Planning for Cross-border Acquisitions, Mergers and Joint Ventures PDF Download
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Languages : en
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Collection of materials for the 10th Annual International Tax Conference of the Council for International Tax Education, held in Los Angeles on 31 January - 2 February 2000.
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Languages : en
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Book Description
Collection of materials for the 10th Annual International Tax Conference of the Council for International Tax Education, held in Los Angeles on 31 January - 2 February 2000.
Author: Peter H. Blessing
Publisher:
ISBN: 9789041161222
Category : Consolidation and merger of corporations
Languages : en
Pages : 0
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Book Description
This user-friendly resource is comprised of two complementary parts: first, a practical overview of certain key tax aspects of international transactions that have general application, followed by twenty-one detailed country profiles, pinpointing each jurisdiction's handling of such areas of concern as entity classification, taxable transactions, tax-free transactions (both domestically and cross-border), loss planning, IP planning, compensation arrangements, acquisition financing, JV planning, VAT issues, tax treaty usage, and much more. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations. The work will assist in planning and evaluating strategies for transactions in single and multiple jurisdictions, as well as in implementing them. It further will allow an easy comparison of key tax aspects in major jurisdictions. Addressing an important information gap in an area of widespread commercial concern, this resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals. Contributing authors: Marti Adroer, Soo-Jeong Ahn, Javier Asensio, Daniel Bader, Xavier Berre, Peter H. Blessing, Jose Carlos Silva, Agn�s Charpenet, David Caupers, Stephan Eilers, Shefali Goradia, Gabriel Gotlib, Daniel Gustafsson, Richard Hendriks, Werner Heyvaert, Soraya M. Jamal, John Jangwoon Kwak, Josh Jones, Sophie Jouniaux, Janne Juusela, Michael Khayat, Kirsten Kjellander, Robert Kopstein, Daniel Lehmann, Sanna Lindqvist, Margriet E. Lukkien, Ricardo Luiz Becker, Victor Matchekhin, Michael McGowan, Patrick Mears, Riccardo Michelutti, Takeo Mizutani, Stephen Nelson, Janette Pantry, Peter Reinarz, Eric N. Roose, M�nica Sada Garibay, Martin Schiessl, Michael H. Shikuma, Ansgar A. Simon, Jin Soo Soh, James Smith, Raoul Stocker, Andrew Stuart, Peng Tao, Peter Utterstr�m, Adalberto Valadez, Maarten J.M. van der Weijden, Richard Vann, Chris Van Loan, Fernando M. Vaquero, Fl�vio Veitzman, Sonia Velasco and Sabrina Wong. "
Author: Peter H. Blessing
Publisher: Kluwer Law International B.V.
ISBN: 9041190732
Category : Law
Languages : en
Pages : 7048
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Book Description
Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings Fifth Edition Edited by Peter H. Blessing and Ansgar A. Simon About the editors: Peter H. Blessing is Associate Chief Counsel, International, at the Office of Chief Counsel of the Internal Revenue Service. Before his appointment in April 2019, he was the head of cross-border corporate transactions in KPMG’s Washington National Tax group. He is a member of Washington National Tax practice of KPMG LLP. His practice involves transactional, advisory and controversy matters, generally in a cross-border context. Peter obtained his LL.M. Taxation from New York University School of Law and has also earned degrees from Princeton University and Columbia Law School. Ansgar A. Simon heads the transactional tax practice of Covington & Burling LLP in New York. His broad-based transactional tax practice covers mergers and acquisitions, corporate restructuring transactions, divestitures, spin-offs, and joint ventures, as well as the financing of such transactions, generally in a cross-border context. Ansgar received his degree in law from Stanford Law School and a PhD in philosophy from the University of California, Los Angeles. About the book: Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings is a practical overview of key tax aspects of international transactions that have general applications, followed by twenty detailed country profiles. Transactional tax planning always is of critical importance to sound deal making. In the international arena, cross-border mergers and acquisitions continue to proliferate as companies seek to maximize global market opportunities. Whether the transaction be strategic or opportunistic, transformational or conventional expansion, third party or internal value-enhancing restructuring, it is crucial for management and counsel to develop a working knowledge of the salient features of the relevant tax law in a broad range of global jurisdictions. This book, now in its fifth edition, distils knowledge of the tax aspects involved in such transactions across international borders. What’s in this book: This book considers each jurisdiction’s handling of areas of concern in international tax planning such as: – entity classification; – structuring taxable transactions; – structuring tax-free transactions (both in domestic and cross-border transactions); – loss planning; – IP planning; – compensation arrangements; – acquisition financing; – joint venture planning; – value added tax issues; and – tax treaty usage. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations. How this will help you: This user-friendly work assists in planning and evaluating strategies for transactions, both nationally and internationally, in single and multiple jurisdictions, as well as in implementing them. This book further allows an easy comparison of key tax aspects in major jurisdictions, thereby providing not only an easy understanding of the key structuring points in context but also critical issue-spotting as well as highlighting potential value-enhancing strategies. Addressing an important information gap in an area of widespread commercial concern, this resource helps international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals to confidently approach challenging situations in both national and international regime. Editors: Peter H. Blessing and Ansgar A. Simon
Author: Peter H. Blessing
Publisher:
ISBN: 9789041132154
Category : Consolidation and merger of corporations
Languages : en
Pages :
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Book Description
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: David J. BenDaniel
Publisher: John Wiley & Sons
ISBN:
Category : Business & Economics
Languages : en
Pages : 632
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Book Description
"By assembling the highly focused works of more than two dozen businessmen, lawyers, accountants, investment bankers, consultants, and experts in such fields as risk management and human resources, BenDaniel and Rosenbloom seamlessly illuminate a complex subject."-Paul E. Graf, President and CEO, Axel Johnson Inc. This fully revised Second Edition shows readers how to find, analyze, structure, and negotiate international deals.
Author:
Publisher:
ISBN:
Category : International business enterprises
Languages : en
Pages : 966
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Author:
Publisher:
ISBN:
Category : Consolidation and merger of corporations
Languages : en
Pages : 1236
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Author:
Publisher:
ISBN:
Category : Consolidation and merger of corporations
Languages : en
Pages : 1406
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Author: Louis S. Freeman
Publisher:
ISBN: 9781402415104
Category : Consolidation and merger of corporations
Languages : en
Pages :
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