Transactions : group company structures
著者
書誌事項
Transactions : group company structures
FT Law & Tax, c1995
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注記
Includes bibliographical references and index
内容説明・目次
内容説明
Each book in the "Transactions Series" takes the key transaction within a particular subject area and offers an illustrative guide on how best to structure and manage such deals. All of the books include examples and practical points that arise regularly in the particular areas of business. Features of the "Transactions Series" include: coverage of lucrative, problematic and topical areas of personal and business tax; a highly practical approach - each book is written and presented in a way that reflects how work is actually done; full of examples, checklists, case studies and planning hints drawn from real life transactions; a distinctive format that makes each book easy and accessible to use. This work offers a practical transactional treatment of all key aspects of tax effective structures for group companies. Each section of the text considers high value transactions with tax planning implications, including: managing group's ACT; liquidation of subsidiaries; transfers of trade intra-group; sale of subsidiaries; reorganization through share exchanges. It includes case studies based on professional experience in order to match clients' real needs.
目次
- Transfer of trade intra-group
- Divisionalisation of group
- Transfer of investment property to dealing company
- Routing disposals through capital loss company
- Routing disposals through surplus ACT company
- Acquiring ACT capacity company
- Waiver of inter-company indebtedness
- Use of ADP to avoid CFC charge
- Orderly termination of trading activities
- Liquidation of subsidiary
- Striking off dormant subsidiaries
- Reorganisation of group involving share exchange
- Reorganisation involving step-up of base cost
- Demerger of trade ('three cornered' demerger)
- Partition of trade
- Sale of subsidiary
- Sale of trade to joint venture
- Managing group's ACT
- Exploiting a subsidiary's ACT capacity
- Fixing the level of management charges
- Setting the level of inter-company pricing with overseas affiliates
- Payment of inter-group interest
- Payment of interest to overseas subsidiaries
- Group relief loss allocation
- Interaction of group relief and loss carry back
- Payments for group relief and surrender of ACT and surrender of tax refunds
- Use of group finance company
- Use of group leasing company
- Claiming tax relief on share and loan note issues
- Planning for VAT group registration
- Computing VAT recovery for holding company.
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