Introduction to the Taxation of Financial Instruments PDF Download
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Author: Henry D. Shereff
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 424
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Book Description
Author: Henry D. Shereff
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 424
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Book Description
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.
Author: Jakob Bundgaard
Publisher: Kluwer Law International B.V.
ISBN: 9041183183
Category : Law
Languages : en
Pages : 498
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Book 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.
Author: Arlene Mary Hibschweiler
Publisher: McGraw Hill Professional
ISBN: 9780071396967
Category : Business & Economics
Languages : en
Pages : 478
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Author: G. M. M. Michielse
Publisher: Springer
ISBN:
Category : Business & Economics
Languages : en
Pages : 376
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Book Description
General overview of the tax treatments of various financial instruments in four important EC Member States: France, Germany, the Netherlands and the United Kingdom, showing the most important tax differences and outlining the points on which EC harmonization is the most imperative, but also the most difficult to realize.
Author: Andrea S. Kramer
Publisher:
ISBN: 9780808056713
Category :
Languages : en
Pages :
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Book Description
Now in its fourth edition, this two-volume bound book provides a road map to work one's way through the tax and regulatory maze of financial products. It details the policies, rules, and interpretations that govern the federal regulation and taxation of securities, crypto currencies, commodities, options, derivatives, and hybrid products. It provides reliable answers to questions about financial markets, financial products, and market participants, and it will help with planning transactions and defending challenged tax positions.
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: Sven-Eric Bärsch
Publisher: Springer Science & Business Media
ISBN: 3642324576
Category : Business & Economics
Languages : en
Pages : 406
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Book Description
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.
Author: Mr.John R. King
Publisher: International Monetary Fund
ISBN: 1451846517
Category : Business & Economics
Languages : en
Pages : 32
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Book Description
Taxes affect the degree and efficiency of financial intermediation in many different ways. This paper summarizes the main tax provisions in OECD countries that affect the overall “tax wedge” between pre-tax returns on investments, and the post-tax yield on the savings that finance them. This tax wedge is shown to vary widely, in individual countries, according to the different ways in which savings are channeled through financial markets. The paper then discusses alternative criteria for assessing tax regimes for financial assets, and summarizes recent trends in OECD countries.
Author: Kevin M. Keyes
Publisher:
ISBN: 9780791328941
Category : Financial instruments
Languages : en
Pages :
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Book Description
