Company Reorganisations - Tax and Tax Planning


Book Description

The tax implications of company reorganization are likely to be of great complexity. This book explains the principal considerations arising from the types of reorganizations undertaken by both UK and international corporations, and it adopts a transaction-based approach to the subject. The material relating to domestic reorganizations is arranged under six main headings - share reorganizations, mergers and amalgamations, reconstructions, de-mergers, management buy-outs and reorganizations before a sole purchase of own shares. This is followed by an examination of international reorganizations, as applicable to UK companies operating overseas and to overseas companies operating in the UK.




Taxation of Company Reorganisations


Book Description

Taxation of Company Reorganisations, Sixth Edition is an essential reference source for tax advisers which covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions. Written by authors with more than fifty years' experience of dealing with clients from small owner-managed businesses to multinational corporate groups, this title includes guidance on the full range of corporate transactions and is applicable to a wide number of organisations. While there is comprehensive coverage of the technical and theoretical meaning of the legislation, the authors have also drawn on their vast practical experience, derived from many years of transaction-based work. This Sixth Edition has been brought fully up to date with recent Finance Acts including FA 2019 and the proposals for FA 2020 that were published in July 2019. It has been reviewed for company and European law and has been updated in relation to the following: - Changes to substantial shareholding exemptions in Finance (No. 2) Act 2017 - Changes to EIS, SEIS and VCT investment schemes in FA 2018 - The introduction of LBTT in Scotland and LTT in Wales - Stamp duty changes proposed for FA 2020 - Enhanced material on the taxation of goodwill and loan relationships on a reorganisation Cases updated since the last edition include: - Gallaher Ltd v Revenue and Customs Commissioners [2019] UKFTT 207 (TC) (on application of s171 TCGA 1992) - Hancock [2019] 1 WLR 3409 (Supreme Court decision) - Trigg [2018] EWCA Civ 17 (Court of Appeal decision)




Corporate Loss Utilisation through Aggressive Tax Planning


Book Description

After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.




Taxation of Company Reorganisations


Book Description

This book is a comprehensive and readable introduction to the complex set of UK tax rules that relate to all types of company reorganizations including reconstructions, amalgamations, and demergers. It describes the relevant personal income tax and pensio







Taxation of Corporate Reorganizations


Book Description




Tax Planning for Troubled Corporations


Book Description

Tax Planning for Troubled Corporations, by noted tax attorneys Gordon D. Henderson and Stuart J. Goldring, clearly outlines the steps involved in corporate bankruptcy proceedings and examines the tax procedural aspects of bankruptcy. This classic treatise provides crystal clear analysis and guidance for any company considering bankruptcy filing and for tax, financial and legal advisors to such companies. It examines the full gamut of tax aspects, consequences and considerations of bankruptcy and non-bankruptcy restructuring of financially troubled businesses -- from the corporation's initial tax payment and reporting obligations through the claims resolution process, to the payment and discharge of tax claims pursuant to a confirmed Chapter 11 plan.




Taxation of Company Reorganisations


Book Description




Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings


Book Description

This classic handbook has once again been updated from cover to cover, assuring its secure place as the preeminent tax practice guide for the conduct of international business transactions. The user-friendly structure has been maintained—first, a hands-on overview of certain key tax aspects of international transactions that have general application (including a chapter on special issues for transactions touching the European Union), followed by detailed country profiles that offer solutions designed to maximize effective tax planning and satisfy compliance obligations in twenty key global trading jurisdictions. The expert country-by-country contributors explain each jurisdiction’s approach to the critical areas of concern in transactional tax planning, addressing among other issues: entity classification; taxable transactions; tax-free transactions (both domestic and cross-border); loss and other tax attribute planning; intellectual property transactions; compensation arrangements; acquisition financing; joint ventures; transfer pricing; VAT; and tax treaty usage. Because it is crucial for management and counsel to develop a working knowledge of the salient aspects of the relevant law in a broad range of global jurisdictions, the work is of immeasurable value in assessing, strategizing, and implementing international transactions while also allowing quick jurisdictional comparison of key tax aspects. Addressing an important information gap in an area of widespread commercial concern, this incomparable resource will be welcomed by international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals.