Structuring Cross Border Transactions
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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.
Eu Tax Disclosure Rules
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Author : Haase, Florian
language : en
Publisher: Edward Elgar Publishing
Release Date : 2021-08-27
Eu Tax Disclosure Rules written by Haase, Florian and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-08-27 with Law categories.
This book provides a comprehensive, practical guide to the 6th amendment of Council Directive 2011/16/EU on administrative cooperation in the field of taxation (known as DAC6). Florian Haase offers insight and clarity into the mandatory reporting obligations imposed by DAC6 on intermediaries engaged in tax matters involving cross-border activities, and in some cases taxpayers themselves, as well as the characteristics or ‘hallmarks’ outlined in the Directive that trigger these obligations.
The Use Of Hybrid Financial Instruments In Cross Border Transactions
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Author :
language : en
Publisher:
Release Date : 1990
The Use Of Hybrid Financial Instruments In Cross Border Transactions written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1990 with International business enterprises categories.
Tax Planning For International Mergers Acquisitions Joint Ventures And Restructurings 5th Edition
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Author : Peter H. Blessing
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2020-03-10
Tax Planning For International Mergers Acquisitions Joint Ventures And Restructurings 5th Edition written by Peter H. Blessing 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 2020-03-10 with Law categories.
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
Trade Finance
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Author : International Trade Centre
language : en
Publisher: United Nations
Release Date : 2004-04-30
Trade Finance written by International Trade Centre and has been published by United Nations this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004-04-30 with Political Science categories.
This study introduces the basics of financing and security mechanisms in international trade and describes the methods of maximizing the benefits and neutralizing the risks involved. It examines issues such as the law and practice of international payments, financing and re-financing of mid and long term receivables, and securing the repayment of credits. It also discusses dispute resolution, international institutions related to trade finance and various model contractual provisions. A glossary is included.
Taxmann S Cross Border Transactions Under Tax Laws Fema Practical Commentary Covering Income Tax Including International Tax Transfer Pricing Gst Customs Fema Etc With Case Laws
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Author : Dr. G. Gokul Kishore
language : en
Publisher: Taxmann Publications Private Limited
Release Date : 2023-05-26
Taxmann S Cross Border Transactions Under Tax Laws Fema Practical Commentary Covering Income Tax Including International Tax Transfer Pricing Gst Customs Fema Etc With Case Laws written by Dr. G. Gokul Kishore and has been published by Taxmann Publications Private Limited this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-05-26 with Law categories.
This book provides practical guidance based on judicial interpretation of the law and rules. It also provides an easy-to-understand commentary (with departmental clarifications) on cross-border transactions with respect to the following laws: • Income Tax (including International Tax & Transfer Pricing) • Goods & Services Tax (GST) • Customs • Foreign Exchange Management Act (FEMA) This book will be helpful for practitioners, members of the bar & bench and industry, and assessing officers. The Present Publication is the 3rd Edition, amended by the Finance Act 2023 and updated till 1st May 2023. This book is authored by Dr. Gokul Kishore & R. Subhashree, with the following noteworthy features: • [Easy-to-Understand Practical Commentary] covering: o Income Tax (including International Tax & Transfer Pricing) § Implications of International Transactions § Adoption of Appropriate Transfer Pricing (TP) § Comprehending the Creation of Permanent Establishment (PE) and Double Taxation Avoidance Arrangements (DTAA) § Ensuring Compliance with Withholding Obligations when payment is made to non-resident § Issues relating to Royalty & Fees for Technical Services (FTS), Tax Residency and Foreign Tax Credit (FTC) o GST § Examination of Cross-Border Services by applying Place of Supply & Export of Service provisions under the Integrated Goods and Services Tax Act (IGST), besides analyzing benefits to exporters o Customs § Valuation of Imported Goods under Customs Valuation Rules, when transaction value as declared by importer is not accepted § Availing Customs Duty Exemptions § Duty Remission and Rewards under various Export Promotion Schemes as provided in Foreign Trade Policy 2023 o FEMA § Compliance with Provisions of FEMA on Receipts and Payments for Export and Imports • [Exhaustive Discussion on both Basic Concepts and Issues faced by the Industry] combined with essential commentary on statutory provisions and the jurisprudence. • [Cross-references to other Chapters] wherever implications need to be understood The structure of the book is as follows: • [Chapter 1 | Customs Valuation] discusses Article VII of GATT, Customs Valuation Agreement, Section 14 of Customs Act, 1962, Customs Valuation Rules (for imported goods) and Export Valuation Rules with relevant judgments and orders. Pointers relating to transfer pricing issues have also been mentioned in this chapter • [Chapter 2 | Transfer Pricing] analyzes international transactions, associated enterprises, comparables, methods of determining Arms Length Price, TP challenges in India as per the UN TP Manual and judicial rulings, creation of marketing intangibles and TP issues relating to AMP expenses. TP assessment, adjustment and appellate remedy have also been included. To provide a 360° perspective, secondary adjustment, Country by Country Reporting (CbCr), thin capitalization, Cost Contribution Arrangements, intra-group services and cost-sharing arrangements have been succinctly covered • [Chapter 3 | Permanent Establishment & DTAAs] discusses taxing powers and sources of income. The concept of PE and types of PE have been explained through the relevant articles in various DTAAs, along with treatment by the Indian judiciary and ITAT. The attribution of profits to PE, which has significant practical implications, has also been discussed • [Chapter 4 | Incomes other than Business Income, Withholding Obligations and Foreign Tax Credit] is broad-based and to the extent relevant to cross-border transactions; it provides a commentary laced with practical guidance on residency, the definition of interest, jurisdiction to tax, dividends paid or received, taxation of royalty, FTS, salary, capital gains, other income, withholding obligations, FTC, the requirement to file the return and the concept of the representative assessee • [Chapter 5 | Import & Export under IGST Act] as applicable to import and export of goods, import of services and export of services, along with the provisions on the place of supply and refund mechanism, forms the fifth chapter • [Chapter 6 | Customs Exemption and Export Promotion Schemes under FTP] Considering the relevance to cross-border trade, Customs Duty exemptions and export promotion schemes under Foreign Trade Policy 2023 (FTP) have been discussed in the sixth chapter. • [Chapter 7 | Export and Import under FEMA & Regulations] Knowledge of obligations and provisions applicable to export and import under FEMA and regulations thereunder is integral to cross-border transactions. Therefore, a concise commentary on the same has been provided in Chapter 7 • [Chapter 8 | Dispute Resolution] Dispute resolution mechanisms under IGST Act and Customs Act, along with alternative dispute resolution under Income Tax Act, have been included. Chapter 8 also provides a broad overview of the statutory remedies available to exporters and importers
International Transfer Pricing
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Author : J Michael Elliot
language : en
Publisher: CIMA Publishing
Release Date : 2000-12-31
International Transfer Pricing written by J Michael Elliot and has been published by CIMA Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2000-12-31 with Architecture categories.
This report sheds light on international transfer pricing (ITP) by moving away from primary tax focus. By examining one specific intra-group, cross-border transaction between 12 MNEs, the resulting micro-level of analysis provides a qualitative, in-depth understanding of ITP in various sectors.
Cross Border Transactions Between Related Companies A Summary Of Tax Rules
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Author : Ernst & Whinney
language : en
Publisher: Springer
Release Date : 1985
Cross Border Transactions Between Related Companies A Summary Of Tax Rules written by Ernst & Whinney and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1985 with Business & Economics categories.
Comparative study providing an outline of transfer pricing rules and related issues in some countries (Australia, Belgium, Brazil, Canada, Denmark, Finland, France, German Federal Republic, Hong Kong, Ireland, Italy, Japan, Mexico, the Netherlands, New Zealand, Norway, Saudi Arabia, Singapore, SOuth Africa, SPain, Sweden, Switzerland, United Kingdom, U.S.A., Venezuela.
Due Diligence For Global Deal Making
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Author : Arthur H. Rosenbloom
language : en
Publisher: John Wiley & Sons
Release Date : 2010-05-27
Due Diligence For Global Deal Making written by Arthur H. Rosenbloom and has been published by John Wiley & Sons this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010-05-27 with Business & Economics categories.
Companies of all sizes have been initiating international transactions--mergers and acquisitions, joint ventures, strategic alliances, and private placements--in record numbers. Targeted due diligence is crucial to effectively research, value, and complete these complex deals. With an evolving climate of uncertainty and new, unpredictable threats to business, it is more essential than ever before. Due Diligence for Global Deal Making is an invaluable guidebook for companies trying to capitalize on the opportunities in both developed and emerging cross-border markets. All too often global transactions fail to meet the parties' expectations, and the leading culprit is inadequate due diligence. Especially when the target partner lacks a financial performance track record and significant assets, expanding businesses must answer difficult questions, such as: Why (if at all) do this deal? What are the rules going in, and what happens if things go wrong? Where are the tax, legal, financial, and operational traps, and what are the opportunities? This book provides what’s needed to avoid devastating mistakes and to master the steps that ensure success: Expert analysis, insights, and strategies from experienced practitioners and leading authorities in cross-border matters In-depth coverage of critical topics decision makers need to understand in order to succeed in cross-border transactions--from corporate planning to operational, financial, legal, tax, accounting, and people/organizational considerations Best practices of corporate investors and professional advisers in conducting critical due diligence Noted experts discuss critical topics corporate executives--and all those involved with their company's legal, operational, accounting, and tax matters--need to know to successfully complete complex global transactions today.