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Tax Arbitrage through Cross-Border Financial Engineering ~ Explores tax arbitrage opportunities ensuing from financial engineering techniques with cross-border financial instruments, making use of complex types of arrangements such as hybrids, synthetics, and non-traditional financial instruments, which are
Tax Arbitrage through Cross-Border Financial Engineering ~ Series in International Taxation Series Volume 50 . Tax Arbitrage through Cross-Border Financial Engineering is a comprehensive exploration of tax arbitrage opportunities ensuing from financial engineering techniques with cross-border financial instruments. You’ll discover how to enhance your practice by making use of complex types of arrangements such as hybrids, synthetics, and non .
Tax Arbitrage through Cross-Border Financial Engineering ~ Tax Arbitrage through Cross-Border Financial Engineering. is a comprehensive exploration of tax arbitrage opportunities ensuing from financial engineering techniques with cross-border financial instruments.. You'll discover how to enhance your practice by making use of complex types of arrangements such as hybrids, synthetics, and non-traditional financial instruments, which are able to meet .
Jakob Bundgaard* Cross-Border Tax Arbitrage Using Inbound ~ 1. Background: Hybrid Financial Instruments, Tax Arbitrage and Tax Policy The use of hybrid financial instruments has increased dramatically in recent years in both the private and pub-lic sectors.1 It is a well-known fact that hybrid financial instruments give rise to some difficult problems in the field of international tax law.
Tax Arbitrage through Cross-Border Financial Engineering ~ Tax Arbitrage through Cross-Border Financial Engineering is a comprehensive exploration of tax arbitrage opportunities ensuing from financial engineering techniques with cross-border financial instruments.You’ll discover how to enhance your practice by making use of complex types of arrangements such as hybrids, synthetics, and non-traditional financial instruments, which are able to meet .
THE DILEMMA OF INTERNATIONAL TAX ARBITRAGE: A COMPARATIVE ~ the dilemma of international tax arbitrage: a comparative analysis using the cases of hybrid financial instruments and cross-border leasing shay nisan menuchin a thesis submitted to the department of law of the london school of economics and political science for the degree of doctor of philosophy london, uk. 2005
Tax avoidance with cross-border hybrid instruments ~ Fig. 1a provides an illustration of a demarcation rule in the two-dimensional case (N = 2).The shaded square represents the full set of financial instruments ℤ. The demarcation line depicts the subset of financial instruments satisfying that G(z 1,z 2) = x.This is the set of marginal hybrid instruments with characteristics that are just sufficiently close to equity to be categorized as such .
Cross-Border Investing with Tax Arbitrage: The Case of ~ the importance of tax barriers to international market integration [see, e.g., Bekaert (1995)] and tax policy, in particular effects on risk sharing and the cost of capital of using a dividend tax credit to achieve integration of the corporate and personal tax [Harris, Hubbard and Kemsley (1998)].
Recent Developments in the Taxation of Cross-Border Hybrid ~ Instruments International Tax Institute, September 22, 2011 . Lucy W. Farr. . (potential double tax or an arbitrage). 23 Example: Cross Border Gold-linked Notes . Recent Developments in the Taxation of Cross-Border Hybrid Instruments International Tax Institute, September 22, 2011 .
Taxation of cross-border mergers and acquisitions ~ for US tax purposes but as a disregarded entity for foreign tax purposes), hybrid instruments (e.g. an instrument that is treated as debt in the payor jurisdiction and equity in the recipient jurisdiction), hybrid transfers (e.g. a repo transaction treated as a secured financing in one jurisdiction and as a
Cross-border tax arbitrage using inbound hybrid financial ~ This article analyses a new provision in Danish tax law - Sec. 2B of the Corporation Tax Act - aimed at curbing cross-border tax arbitrage through the use of hybrid financial instruments. The effect of the provision is to reclassify debt between group companies as equity, and thus interest into dividends.
Taxation of cross-border mergers and acquisitions ~ taxation while also addressing tax evasion. — With corporate tax hikes and increasingly complex anti-avoidance rules, Chile’s recent tax changes have to some extent bucked international trends, but the country’s strong social and political stability continues to attract investors. — The tax-friendly countries and jurisdictions of Central
Taxation of Hybrid Financial Instruments and the ~ 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.
Cross-Border Tax Arbitrage / SpringerLink ~ Abstract. This chapter covers the practice of taking advantage of differential tax treatments across tax jurisdictions. It also analyzes the most commonly used schemes such as the Dual No Tax Residence, the Original Issue Discount, the Hybrid Financing Instrument, the Feline Prides, the REPO, the Lease-Back Transaction, the Entity Classification, the Dual Resident Company, and the Double .
United States - Taxation of cross-border M&A - KPMG Global ~ United States (US) law regarding mergers and acquisitions (M&A) is extensive and complex. Guidance for applying the provisions of the Internal Revenue Code of 1986, as amended (Code), is provided by the federal government, generally by the Internal Revenue Service (IRS) in revenue rulings, revenue procedures, private letter rulings, announcements, notices andTreasury Department regulations .
International - Cross-Border Tax Arbitrage - IBFD ~ 10 July 2012 - This article is the eighth of a series of articles that will feature the sessions to be presented at the 66th Congress of the International Fiscal Association (IFA), to be held in Boston September 30 through October 4. Readers who wish to register ma
Tax avoidance with cross-border hybrid instruments ~ Hybrid instruments may be treated as debt in one country and equity in another. • Firms can use hybrid instruments to reduce effective taxation on foreign investment. • Tax avoidance with hybrid instruments is facilitated by conduit finance structures. • There exists a global policy equilibrium where no countries use anti-avoidance rules.
Cross-Border Taxation - The Tax Adviser ~ Income earned by a foreign taxpayer through the rental of U.S. real property may be characterized as either FDAP income subject to a 30% withholding tax on a gross basis (i.e., without the allowance of any deductions connected to the income) or ECI subject to tax on a net basis, depending on the presence of a U.S. trade or business. 52 Although .
Cross Border Tax ~ After working in Beverly Hills, CA and Toronto, ON in the tax department of national firms, Steve moved to Toronto in 1993 and started Crossborder Tax Services in 1997. Crossborder Tax Services provides US and Canadian tax consulting and compliance services to individuals, corporations and other tax professionals in Canada and the U.S.
Journal of Public Economics - Niels Johannesen ~ model of hybrid instruments and show that, for a given pair of countries, firms in at least one country and sometimes in both can avoid taxes on investment in the other country with a cross-border hybrid instrument. We then investigate why countries tend to allow the use of hybrid instruments for tax avoidance and show
Taxation of Cross-Border Hybrid Finance - A Legal Analysis ~ Although hybrid instruments may be issued for a variety of non-tax reasons, taxation issues have a considerable impact on management's financing decisions with respect to hybrid instruments. Tax .
Tax Arbitrage - investopedia ~ Tax arbitrage is the practice of profiting from differences that arise from the ways transactions are treated for tax purposes. The complexity of tax codes often allows for many incentives which .
The Taxation of Debt, Equity, and Hybrid Arrangements ~ by derivatives, hybrids, financial engineering, asset replication, and * Of the Commonwealth Treasury, Canberra. This article was originally presented as a paper at the Australian Taxation Studies Program/University of New South Wales Interna-tional Spring School on Derivatives and Synthetic Equities held at Coogee (Sydney) in October 1998.
The basic framework of cross-border taxation ~ Marshall McLuhan’s global village is a fact of our times and so is the necessity of adapting tax practices to accommodate it. For a detailed discussion of the issues in this area, see “Cross-Border Taxation,” by Barry Leibowicz, Esq., in the March 2013 issue of The Tax Adviser. —Alistair M. Nevius, editor-in-chief The Tax Adviser
Tax-efficient cross-border finance structures ~ — Tax deduction generally granted if loan debt is: • Contracted in the proper interest of the debtor company. • Properly recorded in its accounts. — Thin capitalization rules • Interest rate ceiling: maximum deductible interests limited to the annual average of the effective interest rates applied by financial institutions.