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)




The Financial Times Guide to Business Start Up 2014


Book Description

Whether you’re about to start your own business or have already taken the plunge and want to keep everything on track, make sure you have a copy of The Financial Times Guide to Business Start Up on your shelf. Annually updated, this edition covers the latest legal and financial changes you need to be aware of following the 2013 Budget. There’s also essential new content on shaping up for the digital marketplace and how to develop your online presence, benefit from social media and advertise effectively online. This guide takes you through every important aspect of starting and running a business, including developing your idea and getting financial backing, recruiting staff, building customer relationships, sales, marketing, VAT and much more. Everything you need to know to make your start up a success.




Taxation of Derivatives


Book Description

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.




Tolley's Guide to Employee Share Schemes


Book Description

With this new edition of Tolley's Guide to Employee Share Schemes you can be sure you're giving the best, up-to-date guidance on implementing employee share schemes which will save money for your client.The new edition of this title evaluates the range of employee share schemes available, looking at their processes, the statutory and regulatory requirements, HMRC's interpretation of share scheme issues and most importantly the tax benefits associated with the various schemes. You can rely on the detailed and expert guidance contained in this title to ensure you choose the most effective and tax efficient employee share scheme. This indispensable guide is written in a clear, practical style and includes worked examples and case studies throughout.




Tolley's Capital Gains Tax 2013-14


Book Description

Tolley's Capital Gains Tax provides the definitive, yet straightforward, concise account of the law and practice relating to this complex tax. Corporation tax on chargeable gains is also fully covered. Its practical alphabetical presentation and extensive cross-referencing between chapters, backed up by full details of source materials, will lead you directly to all the information you want. Price includes a post-Budget 2013 Supplement published in April and a full edition post-Finance Act 2013 published in September (also available separately).




Tolley's Capital Gains Tax 2013-14 Main Annual


Book Description

Tolley's Capital Gains Tax provides the definitive, yet straightforward, concise account of the law and practice relating to this complex tax. Corporation tax on chargeable gains is also fully covered. the practical alphabetical presentation and extensive cross-referencing between chapters, backed up by full details of source materials, will lead directly to all the information the tax practitioner requires.




Principles of International Taxation


Book Description

The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.




United States Code


Book Description




The Wheels That Drove New York


Book Description

The Wheels That Drove New York tells the fascinating story of how a public transportation system helped transform a small trading community on the southern tip of Manhattan island to a world financial capital that is home to more than 8,000,000 people. From the earliest days of horse-drawn conveyances to the wonders of one of the world's largest and most efficient subways, the story links the developing history of the City itself to the growth and development of its public transit system. Along the way, the key role of played by the inventors, builders, financiers, and managers of the system are highlighted. New York began as a fur trading outpost run by the Dutch West India Company, established after the discovery and exploration of New York Harbor and its great river by Henry Hudson. It was eventually taken over by the British, and the magnificent harbor provided for a growing center of trade. Trade spurred industry, initially those needed to support the shipping industry, later spreading to various products for export. When DeWitt Clinton built the Erie Canal, which linked New York Harbor to the Great Lakes, New York became the center of trade for all products moving into and out of the mid-west. As industry grew, New York became a magnate for immigrants seeking refuge in a new land of opportunity. The City's population continued to expand. Both water and land barriers, however, forced virtually the entire population to live south of what is now 14th Street. Densities grew dangerously, and brought both disease and conflict to the poorer quarters of the Five Towns. To expand, the City needed to conquer land and water barriers, primarily with a public transportation system. By the time of the Civil War, the City was at a breaking point. The horse-drawn public conveyances that had provided all of the public transportation services since the 1820's needed to be replaced with something more effective and efficient. First came the elevated railroads, initially powered by steam engines. With the invention of electricity and the electric traction motor, the elevated's were electrified, and a trolley system emerged. Finally, in 1904, the City opened its first subway. From there, the City's growth to northern Manhattan and to the "outer boroughs" of Brooklyn, Queens, and the Bronx exploded. The Wheels That Drove New York takes us through the present day, and discusses the many challenges that the transit system has had to face over the years. It also traces the conversion of the system from fully private operations (through the elevated railways) to the fully public system that exists today, and the problems that this transformation has created along the way.