Structuring Cross Border Transactions
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Structuring Cross Border Transactions
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Author : Mindy Herzfeld
language : en
Publisher:
Release Date : 2022-10-11
Structuring Cross Border Transactions written by Mindy Herzfeld and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-10-11 with categories.
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.
Structuring Cross Border Transactions
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Author : Mindy Herzfeld
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-10-11
Structuring Cross Border Transactions written by Mindy Herzfeld and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-10-11 with Law categories.
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.
The Law Of Cross Border Business Transactions
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Author : Lutz-Christian wolff
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2017-12-15
The Law Of Cross Border Business Transactions written by Lutz-Christian wolff and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-12-15 with Law categories.
Law of Cross-Border Business Transactions aims at giving a structured introduction to the law and practice of investment deals (e.g., greenfield projects, M&As and hybrid forms) and of non-investment transactions (e.g., trade, technology transfer and services). Cross-border business deals are nowadays routine matters for business entities all over the world and the related legal aspects are becoming more and more complex. This book provides extensive general background information. It also covers numerous specific issues of relevance in the context of cross-border projects. Substantive law issues, procedural aspects and skills-related considerations such as contract drafting, structuring options and cross-cultural lawyering techniques are included, adding up to an unusually comprehensive and useful guide in the field. What’s in this book: The author describes a wide spectrum of transaction types. He explains underlying principles from a conceptual and a comparative point of view with a focus on transactional issues, using case studies from a variety of jurisdictions to demonstrate the significance of particular aspects in the context of multi-jurisdictional legal practice. Among much else, topics include the following: international lawyering and cultural diversity; lex mercatoria; conflict of laws; letters of intent, position papers, heads of agreement, confidentiality and exclusivity agreements; structure and contents of international contracts; e-contracts and smart contracts; protection of intellectual property rights and technology transfer; trade, countertrade and trade financing; insurance; agency and distributorship; greenfield investments and M&As; competition law and merger control; employment law; corporate governance and corporate social responsibility; international taxation; and dispute settlement and cross-border enforcement of awards. This second edition updates the discussion of the different topics comprehensively. It also expands many parts and adds sections in relation to new themes that have gained importance since the publication of the first edition. In particular, it addresses legal issues arising out of the digitalization of the global economy with a special focus on choice-of-law questions, smart contracts, e-bills of lading and online dispute settlement. It also draws attention to the impact of China’s Belt and Road initiative, Brexit and the ‘America First’ foreign policy. How this will help you: Of special value is the author’s precise guidance on drafting techniques and contract practice. The clarity of the presentation, the uncompromising consistency in terms of structure and a large body of references to primary and secondary sources presented in this edition ensure that legal professionals, business managers and academics as well as other interested parties can gain easy access to comprehensive and detailed information across jurisdictions.
Comparative Company Law
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Author : Andreas Cahn
language : en
Publisher: Cambridge University Press
Release Date : 2018-10-04
Comparative Company Law written by Andreas Cahn and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-10-04 with Law categories.
Presents in-depth, comparative analyses of German, UK and US company laws illustrated by leading cases, with German cases in English translation.
International Transactions In Remittances
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Author : Statistical Office of the European Communities
language : en
Publisher: International Monetary Fund
Release Date : 2009
International Transactions In Remittances written by Statistical Office of the European Communities and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Business & Economics categories.
"The International Transactions in Remittance: Guide for Compilers and Users (RCG)" presents concepts, definitions, and classifications related to remittances. It is consistent with the new standards for measuring balance of payments transactions, as contained in the sixth edition of the "Balance of Payments and International Investment Position Manual (BPM6)." These standards are used globally to compile comprehensive and comparable data. "The RCG" identifies the main remittances compilation methods currently being used by compilers and discusses in detail the strengths and weaknesses of each method. It is the first manual providing compilation guidance for remittances and is also the first compilation guide based on concepts set out in "BPM6." Although the "RCG" is primarily aimed at remittances data compilers, it may also be useful for users who wish to understand remittances data.
Mergers Acquisitions And Other Restructuring Activities
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Author : Donald DePamphilis
language : en
Publisher: Elsevier
Release Date : 2009-08-26
Mergers Acquisitions And Other Restructuring Activities written by Donald DePamphilis and has been published by Elsevier this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009-08-26 with Business & Economics categories.
Explaining the real-world of mergers, acquisitions, and restructuring based on his own academic knowledge and experience, Donald DePamphilis shows how deals are done, rather than just explaining the theory behind them.
International Vat Gst Guidelines
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Author : Collectif
language : en
Publisher: OECD
Release Date : 2017-04-12
International Vat Gst Guidelines written by Collectif and has been published by OECD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-04-12 with Business & Economics categories.
Value Added Tax (VAT; also known as Goods and Services Tax, under the acronym GST in a number of OECD countries) has become a major source of revenue for governments around the world. Some 165 countries operated a VAT at the time of the completion of the International VAT/GST Guidelines in 2016, more than twice as many as 25 years before. As VAT continued to spread across the world, international trade in goods and services has also expanded rapidly in an increasingly globalised economy. One consequence of these developments has been the greater interaction between VAT systems, along with growing risks of double taxation and unintended non-taxation in the absence of international VAT co-ordination. The International VAT/GST Guidelines now present a set of internationally agreed standards and recommended approaches to address the issues that arise from the uncoordinated application of national VAT systems in the context of international trade. They focus in particular on trade in services and intangibles, which poses increasingly important challenges for the design and operation of VAT systems worldwide. They notably include the recommended principles and mechanisms to address the challenges for the collection of VAT on cross-border sales of digital products that had been identified in the context of the OECD/G20 Project on Base and Erosion and Profit Shifting (the BEPS Project). These Guidelines were adopted as a Recommendation by the Council of the OECD in September 2016.
German Mergers Acquisitions In The Usa
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Author : Bernd Wübben
language : en
Publisher: Springer Science & Business Media
Release Date : 2007-11-29
German Mergers Acquisitions In The Usa written by Bernd Wübben and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007-11-29 with Business & Economics categories.
Bernd Wübben analyzes the success of 87 German mergers and acquisitions in the USA during the period from 1990 to 2004. Employing a study of the capital markets’ reaction and a survey of acquirers’ executives, he shows that US transactions on average enhanced value for German companies and their shareholders. The author integrates the findings of both methodologies to identify the determinants of transaction success, including characteristics of the German acquiring and the US target companies as well as of the acquisition structure and management.
Global Competitive Strategy
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Author : Daniel F. Spulber
language : en
Publisher: Cambridge University Press
Release Date : 2007-07-02
Global Competitive Strategy written by Daniel F. Spulber and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007-07-02 with Business & Economics categories.
Globalization has fundamentally changed the game of business. Strategic frameworks developed for the analysis of purely domestic business necessarily fall short in the international business context. Managers and business students require alternative approaches to understand and cope with these far-reaching changes. We must learn to think globally in order to succeed. Global Competitive Strategy shows how we can do this by providing a unique set of strategic tools for international business. Such tools include the 'star analysis' that allows strategy makers to integrate geographic information with market information about the global business environment. Also introduced is the 'global value connection' that shows managers how to account for the gains from trade and the costs of trade. Aimed at MBA students taking courses in international strategy, consultants and practising managers with responsibility for strategic development, this 2007 book offers a comprehensive strategic framework for gaining competitive advantage in the global marketplace.
The Australia European Union Free Trade Agreement
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Author : Marc Bungenberg
language : en
Publisher: Springer Nature
Release Date : 2022-02-26
The Australia European Union Free Trade Agreement written by Marc Bungenberg and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-02-26 with Law categories.
This book gathers a selection of peer-reviewed chapters reflecting on the Australia-European Union Free Trade Agreement (AEUFTA). Since 18 June 2018, ten rounds of negotiations for a AEUFTA have been held in a constructive atmosphere, showing a shared commitment to move forward with this ambitious and comprehensive agreement. After a lengthy and arduous process interrupted by the United Kingdom’s withdrawal from the European Union (EU), the United States’ hesitations regarding the EU’s global strategy and the outbreak of the COVID-19 pandemic, the negotiations between Australia and the European Union finally appear to be nearing completion. In challenging times, both parties share a commitment to a positive trade agenda, and to the idea that good trade agreements benefit both sides by boosting jobs, growth and investment. This book explores the challenges, achievements and missed opportunities in the AEUFTA negotiation process, and examines current legal and political relations between the EU, its Member States and Australia. Furthermore, it examines in detail a wide and diverse range of negotiated areas, including digital trade, services, intellectual property rules, trade remedies and investment screening, as well as dispute settlement mechanisms. Lastly, it sheds light on the likely nature of future commercial relations between Australia and the EU. Written by a team of respected authors from leading institutions in both Australia and Europe, the book provides a valuable, interdisciplinary analysis of the AEUFTA.