The Taxation Of Equity Derivatives And Structured Products
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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.
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 Derivatives And Cryptoassets
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Author : Oktavia Weidmann
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2024-06-10
Taxation Of Derivatives And Cryptoassets 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 2024-06-10 with Law categories.
Derivatives stand at the forefront of financial innovation, continually evolving to accommodate new asset classes and risk categories. In the past decade, the growing popularity of cryptoassets and ESG investments has sparked the development of a variety of innovative investment strategies and risk management tools, including crypto and ESG derivatives and related structured products. This new edition has similarly evolved. Using illustrative examples, it provides a comprehensive analysis of the key tax issues associated with derivatives and cryptoassets in domestic and cross-border transactions and presents approaches that tax legislators could adopt to solve them. The new edition also comments on recent trends in global tax policy, such as the OECD Base Erosion and Profit Shifting (BEPS) 1.0 and 2.0 projects. Throughout the book, specific references are made to UK, German, and Swiss tax law. The updated edition addresses the following topics: economic and financial properties of derivatives and cryptoassets; definition of derivatives for tax purposes and its application to crypto derivatives and ESG derivatives, among others; accounting treatment of derivatives and cryptoassets under IFRS, UK, German and US GAAP; current tax legislation and policy alternatives to the taxation of derivatives and cryptoassets; characterisation of derivatives gains and losses as income or capital, and equity or debt; accounting and taxation treatment of hedging transactions involving derivatives or cryptoassets; accounting and taxation rules applying to structured products and hybrid instruments, including crypto and ESG-linked structured products; withholding taxes on derivatives and the concept of beneficial ownership in domestic and cross-border transactions; and anti-avoidance legislation applying to derivatives and cryptoassets, including the domestic law implementation of BEPS Action 2, the EU Anti-Tax Avoidance Directives (ATAD I and II), the tax transparency rules for cryptoassets (DAC8) and Pillar Two. This comprehensive book analyses recent developments in three intertwined areas of expertise: financial products, accounting and tax law. It will be a valuable resource to tax professionals in their daily practice of advising companies, banks and investment funds. It will also be of interest to government officials and researchers engaged in the taxation of derivatives, cryptoassets, and ESG investment products.
Banking On Failure
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Author : Richard S Collier
language : en
Publisher: Oxford University Press
Release Date : 2020-09-01
Banking On Failure written by Richard S Collier and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-09-01 with Business & Economics categories.
Banks seem all too often involved in cases of misconduct, particularly involving the exploitation of tax systems. Banking on Failure explains why and how banks "game the system", accounting for these misconduct cases and analysing the wider implications for financial markets and tax systems. Banking on Failure: Cum-Ex and Why and How Banks Game the System explains why banks design and use structured products to exploit tax systems. It describes one of the biggest and most complex cases - the "cum-ex" scandal - in which hundreds of banks and funds from across the globe participated in the raid on the public exchequers of a number of countries, with losses in the tens of billions of euros. The book then draws on the significance of this case study, and what this tells us about modern banks and their interactions with tax systems. Banking on Failure demonstrates why the exploitation of tax systems by banks is an inevitable feature of the financial markets landscape, and suggests possible responses.
The Handbook Of Equity Derivatives
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Author : Jack Clark Francis
language : en
Publisher: John Wiley & Sons
Release Date : 1999-11-08
The Handbook Of Equity Derivatives written by Jack Clark Francis 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 1999-11-08 with Business & Economics categories.
"There are so many ways to use derivatives that I'm almost surprised when someone doesn't use them. Producers and consumers, investors and issuers, hedgers and speculators, governments and financial institutions: almost everyone can use them." - From the Foreword by Fischer Black, Cocreator of the Black-Scholes Model Never before has there been so much interest in equity derivatives-or so much innovation in structuring these products. As new forms of instruments proliferate, their complexity has grown as well. Even equity derivatives professionals are unlikely to know all the details about every existing structure. With equity derivatives comprising one of the most important components of the capital markets, it's more crucial than ever for every financial professional, specialist and nonspecialist alike, to understand how derivative instruments behave, how they're structured, and how to use them profitably. Edited by leading thinkers in the field, The Handbook of Equity Derivatives, Revised Edition, assembles dozens of experts from universities and Wall Street to help the reader gain a practical grasp of the growing variety of financial instruments and how they work. Contributions from such respected authorities as Gary Gastineau, Mark Rubinstein, J. Gregg Whittaker, and Fischer Black outline the full range of the equity derivatives market, from classic warrants, options, and futures to the new and innovative PERCs, equity swaps, and equity-linked bonds. In nonmathematical language, the book provides a clear introduction to equity derivatives, including the fundamentals and history of options, basic equity structures, and pricing determinants, along with a historical perspective on their evolution. You'll find thorough surveys of: * The burgeoning field of synthetic structures-OTC options and exotics, equity swaps, SPINs, SIGNs, PENs, MITTs, and SuperShares * U.S. and foreign derivatives traded on organized exchanges * Issuer derivative structures, such as warrants, convertibles, PERCs, and unbundled stock units * The unique tax, legal, accounting, and regulatory features of derivatives * How to make the most profitable use of the many equity derivative products * Why some financial instruments succeed-and others fail * The future of the equity derivative market- place Whether you're a finance student becoming familiar with the field or a practicing professional seeking better ways to exploit the tremendous potential of equity derivatives for profit, The Handbook of Equity Derivatives, Revised Edition belongs on your bookshelf. "I heartily endorse The Handbook of Equity Derivatives . . . while the market is continuously inventing new instruments and discarding older ones, the clarity and straightforward nature of the handbook hints at a longevity that will make it useful for many years to come." - Stephen A. Ross Sterling Professor of Economics and Finance, MIT (on the first edition) The most relied-upon resource on equity derivative instruments, their structure, and diverse global markets- now extensively revised and updated Once, equity derivatives were exotic instruments relegated to the hands of specialists. Today, they are among the institutional investor's most popular tools for managing risk and uncovering new profit opportunities. Recognized for its authoritative contributors and its accessible, comprehensive coverage of the entire field, The Handbook of Equity Derivatives has become the standard reference on the subject for specialist and nonspecialist alike. Now, this essential resource has been carefully updated and revised to cover the most current innovations in these continually evolving investment vehicles, including: * Comprehensive coverage of the all-important OTC market * Basic equity structures and how they work * Pricing determinants * PERCs, SPIDERs, and WEBs * The Black-Scholes model * The best uses for and profit potential of new derivative products * Key accounting, tax, and regulatory issues
Combating Fiscal Fraud And Empowering Regulators
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Author : Brigitte Unger
language : en
Publisher: Oxford University Press
Release Date : 2021
Combating Fiscal Fraud And Empowering Regulators written by Brigitte Unger and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021 with Business & Economics categories.
Combating Fiscal Fraud and Empowering Regulators analyzes the impact of new international tax regulations on the scope and scale of tax evasion, tax avoidance, and money laundering
How To Invest In Structured Products
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Author : Andreas Bluemke
language : en
Publisher: John Wiley & Sons
Release Date : 2009-09-15
How To Invest In Structured Products written by Andreas Bluemke 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 2009-09-15 with Business & Economics categories.
This book is essential in understanding, investing and risk managing the holy grail of investments - structured products. The book begins by introducing structured products by way of a basic guide so that readers will be able to understand a payoff graphic, read a termsheet or assess a payoff formula, before moving on to the key asset classes and their peculiarities. Readers will then move on to the more advanced subjects such as structured products construction and behaviour during their lifetime. It also explains how to avoid important pitfalls in products across all asset classes, pitfalls that have led to huge losses over recent years, including detailed coverage of counterparty risk, the fall of Lehman Brothers and other key aspects of the financial crisis related to structured products. The second part of the book presents an original approach to implementing structured products in a portfolio. Key features include: A comprehensive list of factors an investor needs to take into consideration before investing. This makes it a great help to any buyer of structured products; Unbiased advice on product investments across several asset classes: equities, fixed income, foreign exchange and commodities; Guidance on how to implement structured products in a portfolio context; A comprehensive questionnaire that will help investors to define their own investment preferences, allowing for a greater precision when facing investment decisions; An original approach determining the typical distribution of returns for major product types, essential for product classification and optimal portfolio implementation purposes; Written in a fresh, clear and understandable style, with many figures illustrating the products and very little mathematics. This book will enable you to better comprehend the use of structured products in everyday banking, quickly analyzing a product, assessing which of your clients it suits, and recognizing its major pitfalls. You will be able to see the added value versus the cost of a product and if the payoff is compatible with the market expectations.
Hybrid Financial Instruments Double Non Taxation And Linking Rules
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Author : Félix Daniel Martínez Laguna
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-06-12
Hybrid Financial Instruments Double Non Taxation And Linking Rules written by Félix Daniel Martínez Laguna 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 2019-06-12 with Law categories.
Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.
Derivative Products And Pricing
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Author : Satyajit Das
language : en
Publisher: John Wiley & Sons
Release Date : 2005-10-06
Derivative Products And Pricing written by Satyajit Das 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 2005-10-06 with Business & Economics categories.
Derivative Products & Pricing consists of 4 Parts divided into 16 chapters covering the role and function of derivatives, basic derivative instruments (exchange traded products (futures and options on future contracts) and over-the-counter products (forwards, options and swaps)), the pricing and valuation of derivatives instruments, derivative trading and portfolio management.
Dividend Tax Abuse
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Author : United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations
language : en
Publisher:
Release Date : 2008
Dividend Tax Abuse written by United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Dividends categories.