Author : Kevin Walton
Publisher : Tolley
Page : 1070 pages
File Size : 14,74 MB
Release : 2006
Category : Capital gains tax
ISBN : 9780754529750
This account of the law and practice relating to capital gains tax also covers corporation tax on chargeable gains. Presented alphabetically, with cross-referencing between chapters, details of source materials are included with worked examples.
Author : Raymond Adema
Publisher : Kluwer Law International B.V.
Page : 578 pages
File Size : 30,54 MB
Release : 2009-01-01
Category : Law
ISBN : 9041128395
This book examines the taxation of Undertakings for the Collective Investment in Transferable Securities (UCITS) in Austria, Germany, the Netherlands, and the United Kingdom. It analyses the tax consequences of the cross-border trade in units of UCITS for unitholders residing in the countries examined. It also features recommendations to remove the tax advantages and disadvantages that occur in cross-border trading.
Author : Moshe Shekel
Publisher : Routledge
Page : 601 pages
File Size : 21,64 MB
Release : 2009-05-28
Category : Business & Economics
ISBN : 1134021941
Time itself creates advantages and disadvantages in the field of taxation. The timing of the recognition of income and expenses for tax purposes has two main implications: firstly, for the timing of the collection of tax, and secondly, for the question of quantification, i.e., how to ensure that the difference between the timing of the recognition of income or expenses, as opposed to the respective dates on which the amounts are actually received or paid, does not distort the determination of the amount of chargeable income. The time component is a weapon in the confrontation between the opposing motivations of the taxpayers and the tax authorities. In any given fiscal year, taxpayers seek to present a minimal picture of their chargeable income, by "deferring" the recognition of income or "advancing" the recognition of expenses. As opposed to this, the tax authorities adopt the opposite strategy: maximizing taxable "profit" in any given year. This book critically examines the various approaches that have been adopted in the tax systems in the UK, the US and Israel in relation to the timing of income recognition and expenses for tax purposes. It suggests an innovative tax model that identifies the advantages that arise to the taxpayer as a result of the differences between the timing of the recognition of income and expenses, and the timing of the receipt of the revenue or the payment of a liability, and taxes only that advantage.
Author : Kevin Walton
Publisher : Tolley
Page : 44 pages
File Size : 38,25 MB
Release : 2007-05
Category : Capital gains tax
ISBN : 9780754532699
This account of the law and practice relating to capital gains tax also covers corporation tax on chargeable gains. Presented alphabetically, with cross-referencing between chapters, details of source materials are included with worked examples.
Author : Malcolm James Finney
Publisher : John Wiley & Sons
Page : 588 pages
File Size : 18,82 MB
Release : 2010-04-01
Category : Business & Economics
ISBN : 0470742313
Wealth Management Planning addresses the major UK tax issues affecting wealth management planning for both the UK domiciled and non-UK domiciled individual. It explains, with numerous worked practical examples, the principles underpinning the three main taxes: income tax; capital gains tax; and inheritance tax. It is aimed at those involved in providing advice in the field of wealth management planning including solicitors, accountants, financial planners, private bankers, trustees, students of tax and law and the layman seeking in depth knowledge. The recent Finance Acts 2006 and 2008, in particular, have modified significantly the tax rules in key areas applicable to wealth management planning. These new tax rules are all addressed in detail in this book and include the pre and post Finance Act 2006 inheritance tax treatment of trusts; the new post Finance Act 2008 residence rules; and the new Finance Act 2008 rules applicable to non-domiciled individuals and the tax treatment of off shore trusts. In view of the increasingly international nature of wealth management planning the book attempts to place the UK tax rules in an international context addressing such issues as: the role of wills in the international arena; the implications of the EU; the suitability of off shore financial centres; and the role and use of double taxation agreements. Appendices bring together useful material produced by HMRC and a detailed bibliography for the interested reader is also included. “ This book gives comprehensive coverage to the complicated subject of taxation for Financial Planners. It will be very valuable to all those Financial Planners who wish to extend their learning and reference and desire to meet the needs of clients”. NICK CANN, CHIEF EXECUTIVE OF THE INSTITUTE OF FINANCIAL PLANNING. “ In this book, Malcolm Finney presents a comprehensive summary of the UK tax rules in straightforward language and with many practical examples. It is a notable achievement to put incomprehensible tax legislation into such readily understandable terms; anyone advising on wealth management will find this to be an invaluable guide to the subject”. MALCOLM GUNN, CONSULTANT, SQUIRE, SANDERS & DEMPSEY “ The author demonstrates considerable skill in explaining complicated tax rules in a manner that makes them easy to assimilate and understand. The book contains Chapter summaries, useful Appendices and numerous worked examples, which provide a very clear, helpful explanation of some difficult tax rules. The book’s contents cover wide areas of the tax system, and yet provide sufficient technical depth to be a valuable point of reference for those involved in wealth management and financial planning”. MARK McLAUGHLIN, MARK McLAUGHLIN ASSOCIATES, MANAGING EDITOR OF TAXATIONWEB “ A valuable new text explaining the tax treatment applicable to financial planning products and strategies for UK domiciled persons (UK resident or expats) and non domiciled UK residents. This book will be of interest to a wide readership ranging from students of law and tax, the interested layman seeking in depth knowledge and professionals including solicitors, accountants, financial planners, private bankers and trustees. Malcolm is to be commended on distilling a vast amount of detailed material into a logical and well ordered framework”. ANDREW PENNEY, MANAGING DIRECTOR, ROTHSCHILD TRUST CORPORATION LTD “ Malcolm Finney’s book is stimulating, innovative and refreshingly practical. Anyone wanting either a high-level understanding of tax principles involved in wealth management or a deeper insight should read this book”. JACOB RIGG, HEAD OF POLICY, SOCIETY OF TRUST AND ESTATE PRACTITIONERS, ST
Author : Oktavia Weidmann
Publisher : Kluwer Law International B.V.
Page : 417 pages
File Size : 25,66 MB
Release : 2015-07-16
Category : Law
ISBN : 9041159835
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.
Author :
Publisher :
Page : 0 pages
File Size : 25,42 MB
Release : 2013
Category :
ISBN : 9780754546450
Author : Great Britain. Treasury
Publisher : The Stationery Office
Page : 244 pages
File Size : 42,18 MB
Release : 2008
Category : Business & Economics
ISBN : 9780101748421
The 2008 Pre-Budget Report presents updated assessments and forecasts of the economy and public finances, and reports on how in the face of major global economic shocks the Government intends to support the economy, businesses and households through these uncertain times while delivering its long-term goals. Measures announced include: temporarily reducing the Value Added Tax (VAT) rate to 15 per cent from1 December 2008 to 31 December 2009; bringing forward £3 billion of capital spending from 2010-11 including introducing a green stimulus supporting low carbon growth and jobs; introducing a new additional higher rate of income tax of 45 per cent for those with incomes above £150,000 from April 2011; increasing national insurance contributions by 0.5 per cent from April 2011; increasing alcohol and tobacco duties; a two pence per litre increase in fuel duty from 1 December). Immediate action to help those individuals and businesses most affected by the economic downturn include: increases in the income tax personal allowance; bringing forward the increase in Child Benefit; increases of the Child Tax Credit and a payment of £60 to all pensioners; help through mortgage rescue and Support for Mortgage Interest schemes for eligible homeowners in difficulty and a commitment from major mortgage lenders not to initiate repossession action within at least three months of an owner-occupier going into arrears; an additional £1.3 billion to support for the unemployed to find a new job; measures to help small and medium-sized enterprises facing credit constraints; a new HMRC Business Payment Support Service to allow businesses in temporary financial difficulty to pay their HMRC tax bills on a timetable they can afford; and more generous tax relief for businesses now making losses and the modification of a number of planned tax reforms, including vehicle excise duty, air passenger duty, and the deferral of the increase in the small companies' rate of corporation tax.
Author : Pete Miller
Publisher : Bloomsbury Publishing
Page : 749 pages
File Size : 31,82 MB
Release : 2020-10-05
Category : Business & Economics
ISBN : 1526511517
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)
Author : Antti Laukkanen
Publisher : IBFD
Page : 487 pages
File Size : 28,61 MB
Release : 2007
Category : Bonds
ISBN : 9087220227
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.
