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OverviewInternational tax arbitrage has come under intense scrutiny since the global financial crisis and is usually portrayed as a form of aggressive tax avoidance. Press coverage has often shown little understanding of the distinction between tax avoidance and tax evasion, describing the legitimate behavior of taxpayer banks, financial institutions, and multinational businesses in emotive terms and often inaccurately. This book looks at tax arbitrage and demystifies its practice. In a world where tax competition, rather than tax harmonization, is the predominant norm, international tax arbitrage is a form of legitimate tax planning. The book starts with a review of some of the press coverage (including recent court cases) and examines campaigns by the Uncut pressure group. It considers the confusion over the boundary between 'legality' and 'morality,' and it covers the responses of tax authorities in major Western economies to calls for tax reform. It also considers the role of jurisdictiona Full Product DetailsAuthor: Nigel FeethamPublisher: Spiramus Press Imprint: Spiramus Press Edition: 1 Dimensions: Width: 15.60cm , Height: 2.10cm , Length: 23.40cm Weight: 0.538kg ISBN: 9781907444432ISBN 10: 1907444432 Pages: 208 Publication Date: 31 March 2011 Audience: General/trade , General Format: Paperback Publisher's Status: Out of Print Availability: Awaiting stock  Table of ContentsIntroduction Summary of the book CHAPTER 1: The bail out – from hero to villain The media feeding frenzy Other side of the Atlantic US Senate “Tax Dodge” Report CHAPTER 2: Tax authorities intervention USA borrower Substance v Form Worldwide taxation and tax credits Securities Lending and Repo Taxpayers file lawsuits in the US claiming tax refunds US docketed cases Who owns the public transport system? CHAPTER 3: Structured finance The ‘art’ of tax avoidance Blowing the whistle Regulators and tax arbitrage When the herd moves in The spirit of the law GAAR Differing approaches Impact of European jurisprudence Are tax havens to blame? CHAPTER 4: The role of jurisdictional competition in tax avoidance arbitrage Uncut Going Dutch Consumer choice Entity classification for tax purposes Every taxpayer’s dream (or not) When the taxman calleth CHAPTER 5: Jurisdictional case review THE UK ITALY FRANCE NEW ZEALAND AUSTRALIA UNITED STATES SOUTH AFRICA Concluding remarks Epilogue Appendix 1: Jurisdictional Arbitrage Financing Transaction Appendix 2: A Code of Practice on Taxation for Banks Appendix 3: Supplementary Guidance NoteReviewsAuthor InformationNigel Feetham is a partner at Hassans International Law Firm. His area of practice includes insurance, funds and structured finance. He has played a major part in some of the most significant developments in the Gibraltar finance sector. Tab Content 6Author Website:Countries AvailableAll regions |
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