Tolley's International Taxation of Corporate Finance

Tolley's International Taxation of Corporate Finance

Author: John Abrahamson

Publisher: Tolley

Published: 2014-08-01

Total Pages: 432

ISBN-13: 9780754551843

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This book introduces and discusses international tax issues relating to corporate finance, group treasury, and banking operations. The book is intended to benefit accountants, lawyers, economists, financial managers and government officials by explaining practical corporate finance international tax issues. These issues include: examples of country tax regimes; corporate finance including issuing shares; debt instruments; bank loans; investment banking activities; and alternative finance such as crowdfunding; microfinance and alternative energy funding; and international tax issues relating to interest and dividend flows; capital gains; and foreign tax credits. The book reviews related topics, including: mergers and acquisitions funding; asset and project finance; securitisation; derivatives; hybrid securities and entities; Islamic financing; bank capital structures; group treasury companies; debt restructuring; and transfer pricing issues. The book is based on Corporate Finance and International Taxation courses presented by the author in London, Paris, Zurich, Lugano, Rio de Janeiro, Mexico City, Hong Kong and Singapore.


Cruise of the Lanikai

Cruise of the Lanikai

Author: Kemp Tolley

Publisher: Naval Institute Press

Published: 2014-01-15

Total Pages: 343

ISBN-13: 1612512232

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In early December 1941 in the Philippines, a young Navy ensign named Kemp Tolley was given his first ship command, an old 76-foot schooner that had once served as a movie prop in John Ford's "The Hurricane." Crewed mostly by Filipinos who did not speak English and armed with a cannon that had last seen service in the Spanish-American War, the Lanikai was under top-secret presidential orders to sail south into waters where the Japanese fleet was thought to be. Ostensibly the crew was to spy on Japanese naval movements, but to Tolley it was clear that their mission was to create an incident that would provoke war. Events overtook the plan, however, when Pearl Harbor was bombed before the Lanikaicould get underway. When Bataan and Corregidor fell, she was ordered to set sail for Australia and became one of the few U.S. naval vessels to escape the Philippines. In this book Tolley tells the saga of her great adventure during these grim, early days of the war and makes history come alive as he regales the reader with details of the operation and an explanation of President Roosevelt's order. Tolley's description of their escape in Japanese warship-infested waters ranks with the best of sea tales, and few will be able to forget the Lanikai's 4,000-mile, three-month odyssey.


Practical Guide to U.S. Transfer Pricing

Practical Guide to U.S. Transfer Pricing

Author: Robert T. Cole

Publisher: Aspen Publishers

Published: 1999

Total Pages: 1302

ISBN-13:

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Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.


Tolley's Guide to Employee Share Schemes

Tolley's Guide to Employee Share Schemes

Author: David Craddock

Publisher: Tolley

Published: 2016-10-26

Total Pages: 900

ISBN-13: 9780754553649

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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.


Evangelpreneur, Revised and Expanded Edition

Evangelpreneur, Revised and Expanded Edition

Author: Josh Tolley

Publisher: BenBella Books

Published: 2021-09-14

Total Pages: 369

ISBN-13: 1637741081

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The truth shall set you free. Ignoring it will cost you a fortune. It has become clear that we are living a lie, and it has brought devastating results: Bankruptcy among churchgoers is equally as high as those who don’t attend. Financial misconduct is destroying marriages, families, individuals, and churches. A record number of churches are in foreclosure. The church teaches us it’s normal to have student loans, car payments, mortgages, and credit cards. It calls poverty a curse but isn’t doing much to correct the problem, and it focuses on tithing and the elimination of personal debt—but debt elimination is not enough. Wouldn’t you rather thrive in your finances and live the life God has called you to? Evangelpreneur will teach you: How to get your financial life to line up with your faith life How to save your family and your church from financial ruin How to recognize if God is calling you to entrepreneurship How to use entrepreneurism to do God’s work on Earth For too long, the faithful have been held hostage by false teaching, bad teaching, and the poor practice of good teaching. It’s time to break free from the bondage tied to financial issues and become an Evangelpreneur.


International Taxation of Banking

International Taxation of Banking

Author: John Abrahamson

Publisher: Kluwer Law International B.V.

Published: 2020-02-20

Total Pages: 468

ISBN-13: 9403510951

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Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.