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The Role of Tax Law in Mergers and Acquisitions

The Role of Tax Law in Mergers and Acquisitions
Author: Chunyang Zhang
Publisher: Kluwer Law International B.V.
Total Pages: 207
Release: 2022-08-08
Genre: Law
ISBN: 9403537620

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Series on International Taxation, Volume 82 The economic value of China’s mergers and acquisitions (M&A) market is exceeded only by that of the United States. However, China’s rapid and somewhat chaotic economic transformation has made the task of taxing M&A transactions in a consistent and prudent manner difficult, leading to a patchwork of fragmented rules that are hard to grasp not only for taxpayers but even for tax professionals and tax officials. Responding to this complex situation, this groundbreaking book explores in detail how income derived from M&A transactions is taxed in China. Using empirical studies in order to provide a first-hand understanding of the context in which the tax law operates, the book critically examines China’s income tax regime for M&A and, based upon this examination, sets out reform proposals. In six informative chapters of great practical relevance, the author thoroughly describes and explains the intersection of such aspects as the following: M&A transactions in the eyes of tax law; disparities between ordinary and special tax treatment; eligibility for special tax treatment; applying taxation principles such as neutrality and equity; continuity of interest doctrine; stock acquisition versus asset acquisition; and adjustment to tax basis. In addition to its empirical research, the analysis makes use of an examination of the rules and theories on taxing M&A in other jurisdictions such as Australia and the United States as part of its proposed blueprint for improving China’s M&A taxation. Drawing on commonly recognized taxation principles, this book definitively sets up the normative criteria for evaluating the income taxation of M&A and reveals the fundamental problems encountered by China’s current regime. Its comprehensive analysis of the Chinese income tax rules for M&A and detailed disclosure of how they are both divergent from and convergent with that of some other major economies will prove of immeasurable value to in-house counsel for multinational corporations, business enterprises with interests in China, taxation consultants, taxation academics, and taxation authorities worldwide.


Corporate Taxation Through the Lens of Mergers & Acquisitions

Corporate Taxation Through the Lens of Mergers & Acquisitions
Author: Samuel Coleman Thompson (Jr.)
Publisher:
Total Pages: 0
Release: 2016
Genre: Business enterprises
ISBN: 9781611631753

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To view or download the 2018 Supplement to this book, click here. This book approaches corporate taxation through the lens of the M&A provisions of the Internal Revenue Code. To ensure that the reader has the appropriate background to explore concepts, Chapter 2 provides an introduction to basic corporate tax principles. Because of the globalization of business activity, this book introduces many of the issues under the Code affecting both inbound and outbound cross-border transactions. The book also looks at various proposals to reform corporate taxation.


Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings, 5th Edition

Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings, 5th Edition
Author: Peter H. Blessing
Publisher: Kluwer Law International B.V.
Total Pages: 7048
Release: 2020-03-10
Genre: Law
ISBN: 9041190732

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Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings Fifth Edition Edited by Peter H. Blessing and Ansgar A. Simon About the editors: Peter H. Blessing is Associate Chief Counsel, International, at the Office of Chief Counsel of the Internal Revenue Service. Before his appointment in April 2019, he was the head of cross-border corporate transactions in KPMG’s Washington National Tax group. He is a member of Washington National Tax practice of KPMG LLP. His practice involves transactional, advisory and controversy matters, generally in a cross-border context. Peter obtained his LL.M. Taxation from New York University School of Law and has also earned degrees from Princeton University and Columbia Law School. Ansgar A. Simon heads the transactional tax practice of Covington & Burling LLP in New York. His broad-based transactional tax practice covers mergers and acquisitions, corporate restructuring transactions, divestitures, spin-offs, and joint ventures, as well as the financing of such transactions, generally in a cross-border context. Ansgar received his degree in law from Stanford Law School and a PhD in philosophy from the University of California, Los Angeles. About the book: Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings is a practical overview of key tax aspects of international transactions that have general applications, followed by twenty detailed country profiles. Transactional tax planning always is of critical importance to sound deal making. In the international arena, cross-border mergers and acquisitions continue to proliferate as companies seek to maximize global market opportunities. Whether the transaction be strategic or opportunistic, transformational or conventional expansion, third party or internal value-enhancing restructuring, it is crucial for management and counsel to develop a working knowledge of the salient features of the relevant tax law in a broad range of global jurisdictions. This book, now in its fifth edition, distils knowledge of the tax aspects involved in such transactions across international borders. What’s in this book: This book considers each jurisdiction’s handling of areas of concern in international tax planning such as: – entity classification; – structuring taxable transactions; – structuring tax-free transactions (both in domestic and cross-border transactions); – loss planning; – IP planning; – compensation arrangements; – acquisition financing; – joint venture planning; – value added tax issues; and – tax treaty usage. The experts in each country suggest solutions designed to maximize effective tax planning and satisfy compliance obligations. How this will help you: This user-friendly work assists in planning and evaluating strategies for transactions, both nationally and internationally, in single and multiple jurisdictions, as well as in implementing them. This book further allows an easy comparison of key tax aspects in major jurisdictions, thereby providing not only an easy understanding of the key structuring points in context but also critical issue-spotting as well as highlighting potential value-enhancing strategies. Addressing an important information gap in an area of widespread commercial concern, this resource helps international tax counsel, corporate and financial services attorneys, and corporate planning and compliance professionals to confidently approach challenging situations in both national and international regime. Editors: Peter H. Blessing and Ansgar A. Simon


Tax Policy Aspects of Mergers and Acquisitions

Tax Policy Aspects of Mergers and Acquisitions
Author: United States. Congress. House. Committee on Ways and Means
Publisher:
Total Pages: 964
Release: 1989
Genre: Consolidation and merger of corporations
ISBN:

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Mergers and Acquisitions

Mergers and Acquisitions
Author: PriceWaterhouseCoopers LLP
Publisher: John Wiley & Sons
Total Pages: 577
Release: 2006-07-13
Genre: Business & Economics
ISBN: 0471998079

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How you handle global tax issues can make or break a deal. Gain a better understanding of these issues with guidance from PricewaterhouseCoopers' Mergers and Acquisitions: A Global Tax Guide When a business engages in a multinational merger or acquisition, dealing with a diverse set of transaction-related tax rules is one of the major challenges to successful implementation. PricewaterhouseCoopers' Mergers and Acquisitions: A Global Tax Guide helps you navigate the complexities unique to these international deals. This invaluable guide focuses on the global tax aspects of mergers and acquisitions to provide you with the information you need to move the deal forward-under a variety of circumstances and in numerous markets. Presenting individual chapters for each of thirty-one countries, this essential handbook provides quick access to the tax information you need, and, as much as possible, reduces the effort required to compare the rules that apply in one jurisdiction with the rules that apply in others. Each country-specific chapter includes an overview of the general approaches to mergers and acquisitions taxation issues as well as detailed information about how the tax authorities in each country apply the rules to various aspects of a transaction. PricewaterhouseCoopers' Mergers and Acquisitions: A Global Tax Guide offers tax planners a foundation of information that they need when involved in international mergers and acquisitions. It also covers many of the finer points of the broader tax issues that arise during planning and negotiation. Many will find this valuable reference to be an indispensable desktop tool in their effort to gain a deeper understanding of the global tax environment.


Mergers and Acquisitions

Mergers and Acquisitions
Author: PricewaterhouseCoopers LLP.
Publisher:
Total Pages: 584
Release: 2006
Genre: Consolidation and merger of corporations
ISBN:

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This book describes the current and anticipated (over the next twelve months) environment for mergers and acquisitions in forty-two specific countries or territories. It provides a general description of the various options available when structuring M & A transactions and introduces relevant tax system(s) and forms (entities) of doing business. .


Tax Aspects of Acquisitions and Mergers

Tax Aspects of Acquisitions and Mergers
Author: Philip Cooke
Publisher: Springer
Total Pages: 160
Release: 1983-10-31
Genre: Business & Economics
ISBN:

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Compilation of country studies by various contributors dealing in a comparative way with the taxation and other related aspects of acquisitions and mergers, both at the domestic level and cross-frontier. Includes general report and country reports on Belgium, Canada, Denmark, France, Germany, Ireland, Italy, Netherlands, Spain, United Kingdom and United States of America.