Taxation Of Derivatives


Taxation Of Derivatives
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Taxation Of Derivatives


Taxation Of Derivatives
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Author : Oktavia Weidmann
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2015-07-16

Taxation Of Derivatives written by Oktavia Weidmann 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 2015-07-16 with Law categories.


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.



Taxation Of Investment Derivatives


Taxation Of Investment Derivatives
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Author : Antti Laukkanen
language : en
Publisher: IBFD
Release Date : 2007

Taxation Of Investment Derivatives written by Antti Laukkanen and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Bonds categories.


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.



The Taxation Of Equity Derivatives And Structured Products


The Taxation Of Equity Derivatives And Structured Products
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Author : T. Rumble
language : en
Publisher: Springer
Release Date : 2002-12-03

The Taxation Of Equity Derivatives And Structured Products written by T. Rumble and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2002-12-03 with Business & Economics categories.


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.



The Use Of Derivatives In Tax Planning


The Use Of Derivatives In Tax Planning
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Author : Frank J. Fabozzi, CFA
language : en
Publisher: John Wiley & Sons
Release Date : 1998-06-20

The Use Of Derivatives In Tax Planning written by Frank J. Fabozzi, CFA 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 1998-06-20 with Business & Economics categories.


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.



Taxation Of Derivatives


Taxation Of Derivatives
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Author : Errol Danziger
language : en
Publisher:
Release Date : 2005-01-01

Taxation Of Derivatives written by Errol Danziger and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005-01-01 with categories.


This book covers the current system of taxation of derivatives, in particular the tax implications of entering into derivative contracts are considered. Because the tax in this area is heavily influenced by and reliant on accounting principles and practice these topics are also covered.References in the text to views expressed by the UK Inland Revenue are the views contained in the Inland Revenue Corporate Finance manual and in other Inland Revenue publications. As far as possible, legal terminology has been used in the text in place of banking terms, with the objective of making the material as clear as possible



Taxation Of Non Equity Derivatives


Taxation Of Non Equity Derivatives
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Author : L. G. Harter (Lawyer)
language : en
Publisher:
Release Date :

Taxation Of Non Equity Derivatives written by L. G. Harter (Lawyer) and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on with Derivative securities categories.


... reviews the U.S. federal income taxation of derivative transactions other than equity derivatives. The taxation of equity derivatives is reviewed in a separate portfolio. See 188 T.M., Taxation of Equity Derivatives. This Portfolio is divided into eight main parts.



Principles Of Financial Derivatives


Principles Of Financial Derivatives
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Author : Steven D. Conlon
language : en
Publisher: Warren Gorham & Lamont
Release Date : 1999-01-01

Principles Of Financial Derivatives written by Steven D. Conlon and has been published by Warren Gorham & Lamont this book supported file pdf, txt, epub, kindle and other format this book has been release on 1999-01-01 with Business & Economics categories.




Accounting And Tax Rules For Derivatives


Accounting And Tax Rules For Derivatives
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Author : Mark J. P. Anson
language : en
Publisher: John Wiley & Sons
Release Date : 1999-11-09

Accounting And Tax Rules For Derivatives written by Mark J. P. Anson 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 1999-11-09 with Business & Economics categories.


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.



Taxation Of Loan Relationships And Derivative Contracts


Taxation Of Loan Relationships And Derivative Contracts
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Author : David Southern
language : en
Publisher: A&C Black
Release Date : 2012-06-01

Taxation Of Loan Relationships And Derivative Contracts written by David Southern and has been published by A&C Black this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-06-01 with Business & Economics categories.


The ninth edition of this well-established work offers comprehensive coverage of all aspect of the taxation of loan relationships and derivative contracts in the UK. It covers the UK's IAS 32/39 and FRS 25/26, loan relationships under IAS, impairment losses and connected company rules, the derivative contracts rules, bifurcation of convertibles, transfer pricing domestic and international, the disregard rules on tax hedging, matching and functional currencies, reconstructions and mergers, repos and stock lending, anti-avoidance rules, corporate debt, loan relationships, derivative contracts, securities taxation, and debt impairment. Particular emphasis is placed on providing worked examples and planning guidance.



Tax Exempt Derivatives


Tax Exempt Derivatives
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Author : Steven D. Conlon
language : en
Publisher: American Bar Association
Release Date : 1994

Tax Exempt Derivatives written by Steven D. Conlon and has been published by American Bar Association this book supported file pdf, txt, epub, kindle and other format this book has been release on 1994 with Business & Economics categories.