Studies in the History of Tax Law, Volume 6


Book Description

These are the papers from the 2012 Cambridge Tax Law History Conference revised and reviewed for publication. The papers include new studies of: income tax law rewrite projects 1914–1956; law and administration in capital allowances 1878– 1950; the 'full amount' in income tax legislation; Sir Josiah Stamp and double income tax; early German income tax treaties and laws concerned with double tax avoidance (1869–1908); the policy of the medicine stamp duty; 'Danegeld' – from Danish tribute to English land tax; religion and charity, a historical perspective; 'Plaintive Glitterati'; a collision of accounting and law, dividends from pre-1914 profits in Australia; the history and development of the taxation profession in the UK and Australia; an inquiry into Dutch to British Colonial Malacca 1824–1839; the taxation history of China; taxing bachelors in America: 1895–1939; Dutch Tax reform under Napoleon; and the last decade of estate duty. The Publisher and authors have dedicated this volume to the memory of John Tiley, Emeritus Professor of the Law of Taxation at the University of Cambridge, who died as it was going to press. The Cambridge History of Tax conferences were his idea and he was responsible for their planning. He also edited all six volumes in the series.




Dimensions of Tax Design


Book Description

The goal of the Mirrlees Review has been to identify what makes a good tax system for an open developed economy in the 21st century and to suggest how the UK tax system could be reformed to move in that direction. As an integral part of the Review, this volume brings together thirteen studies of different dimensions of tax design, plus associated commentaries. These were commissioned from IFS researchers and other international experts, to be of interest and value in their own right, as well as to provide inspiration for the final report of the Review, which is published as a separate volume, Tax by Design. The Commission's work was directed by: Tim Besley Richard Blundell Malcolm Gammie James Poterba The Commission's editorial team: Stuart Adam Stephen Bond Robert Chote Paul Johnson Gareth Myles




UCITS and Taxation


Book Description

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.




International Taxation of Manufacturing and Distribution


Book Description

The most thorough treatment of its subject available, this book introduces and analyses the international tax issues relating to international manufacturing and distribution activities, extending from the tax regime in the country where the manufacturing activities are located, through to regional purchase and sales companies, to the taxation of local country sales companies. The analysis includes the domestic tax laws relating to manufacturing and distribution company profits as well as international tax issues relating to income flows and the payment of dividends. Among the topics and issues analysed in depth are the following: – foreign tax credits; – taxation in the digital economy; – tax incentives; – intellectual property; – group treasury companies; – mergers and acquisitions; – leasing; – derivatives; – controlled foreign corporation provisions; – VAT and customs tariffs; – free trade agreements and customs unions; – transfer pricing; – role of tax treaties; – hedging; – related accounting issues; – deferred tax assets and liabilities; – tax risk management; – supply chain management; – depreciation allowances; and – carry-forward tax losses. The book includes descriptions of 21 country tax systems and ten detailed case studies applying the analysis to specific examples. Detailed up-to-date attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. As a full-scale commentary and analysis of international taxation issues for multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It will prove of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.




Tiley’s Revenue Law


Book Description

This is the ninth edition of John Tiley's major text on revenue law, covering the UK tax system, income tax, capital gains tax and inheritance tax, as well as incorporating sections dealing with corporation tax, international and European tax, savings and charities. This new edition is fully revised and updated with the latest case law, statutory and other developments, including Finance Act 2019. The book is designed for law students taking the subject in the final year of their law degree, or for more advanced courses, and is intended to be of interest to all who enjoy tax law. Its purpose is not only to provide an account of the rules but also to include citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems. Copy the URL below to read a 2021 supplement highlighting new developments since the book's publication in 2019: https://www.bloomsbury.com/media/2v1ej5vw/tileys-revenue-law-supplement-2021.pdf




Taxation of Derivatives and Cryptoassets


Book Description

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.




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)




Wealth Management Planning


Book Description

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




Relationships Between Streetcars and the Built Environment


Book Description

TRB's Transit Cooperative Research Program (TCRP) Synthesis 86: Relationships Between Streetcars and the Built Environment examines selected, built streetcar and trolley systems to trace their evolution, define significant factors, and identify commonalities among levels of success in impacting the built environment.




Opinion Writing and Case Preparation


Book Description

This manual considers the importance of qualities such as clarity, precision and the use of plain English. It examines the stages involved in providing written advice for the client, from initial analysis to final draft.