U.K. reform of taxation of corporate and government debt: what are the implications for U.S. investors?
Article Abstract:
US multinationals should recognize the potential effect of UK efforts to reform debt-financing transactions and investment taxation. Areas such as withholding taxes and related-party structured financing will be dramatically affected if the reform legislation is enacted. The purpose of the UK draft legislation is to provide tax simplification regarding convertible securities and similar instruments and will apply only to government and corporate debt. The legislation covers areas such as loan relationships, accounting methodologies, and anti-abuse.
Publication Name: The International Tax Journal
Subject: Business, international
ISSN: 0097-7314
Year: 1997
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DASTM: problems and planning opportunities
Article Abstract:
The dollar approximate separate transaction method (DASTM) is suitable for US multinational businesses with subsidiaries located in hyperinflationary currency countries. This method enables them to base their accounting on the dollar. Proposed changes in DASTM rules would more closely match these rules to US generally accepted accounting principles, would better match income and loss and would more accurately describe DASTM exchange gain and loss by tracing them directly to the appropriate assets and liabilities.
Publication Name: The International Tax Journal
Subject: Business, international
ISSN: 0097-7314
Year: 1992
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