This book provides the reader with an introduction to the taxation of financial instruments. Beginning with foundational tax and finance concepts, it navigates through common financial instruments and transactions, detailing their tax implications. The instruments covered in this book range from equity and debt to derivatives (including options, forwards, futures, and swaps), while the transactions discussed include short sales, wash sales, tax straddles, and constructive sales. Each chapter begins with a clear explanation of the relevant instrument or transaction before delving into the tax treatment. Suitable for readers curious about financial instruments, tax law, or both, this book offers a useful guide for understanding a complex area of tax law.

Publisher Description

Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.

Presents the results of an analysis of the application of domestic laws and tax treaties to four particular types of instruments: interest rate swaps, financial futures, options to by shares, and bonds issued at a deep discount. Explores the possibility of arriving at consistent treatment of these instruments to provide greater certainty for both tax administrators and the financial markets.

"Taxation of Financial Products is designed for all financial services professionals.It explains the basics of selected financial products and their income tax treatment.Chapters focus on federal income tax basics, mutual funds, annuities, stocks, bonds, life insurance and qualified plans.The information provided is comprehensive and up to date with current tax laws and figures, as well as planning strategies."Taxation of Financial Products is written in plain English, and provides the financial services professional with the proper information needed to help meet clients' financial objectives. Material has been updated to reflect the changes made by the new distribution rules and the Tax Act of 2001, including updates to rules governing qualified plans, catch up contributions and simplification of required minimum distribution rules, and facts, figures, illustrations and examples have been updated. If you are taking this course for CE, the CE exam will automatically be added to your basket when selecting CE credit.Certain states require that a proctor/monitor supervise the exam taking process.

This publication thoroughly reviews the factual background to global trading, analyses the challenges posed to traditional taxation methods and discusses a range of policy options to tackle the problems.