Financial Instruments Tax and Accounting Review

Accounting Accounting for convertibles – May 1999 Mike Lloyd & Harshika Patel, Deloitte & Touche Accounting treatment of securitisations – January 1999 Mike Lloyd, Deloitte & Touche Come again?? – FAS133 –..

Two former derivatives traders at Deutsche Bank have launched creditex, an online platform for trading credit derivatives worldwide. Credit derivatives are used widely by companies wishing to hedge credit risk on a loan or investment. The party..

On a recent visit to meet with the Chancellor, Frits Bolkestein, the European commissioner for taxation and the single market, said that the latest British proposals to breach the impasse over the proposed EU-wide withholding tax would not be..

In the year since FITAR first wrote on the topic, the prospect of a regulatory capital charge for the operational risks run by banks has quietly drawn closer. It has also become clearer that its relevance to those who prepare, audit and read accounts has grown. Now, with the comment period for proposals from both Basel (the Committee on Banking Supervision) and Brussels (the European Commission’s Markets Directorate General) nearly over, it is an appropriate time to review what is most likely to happen to the idea of such a charge.

The International Swaps and Derivatives Association (ISDA) has called on the Basel Committee on Banking Supervision to provide greater detail of the “conceptual framework” behind its goal that banks should hold capital against a broad..

Following on from Stuart Porter’s review, Stephen Weston, Senior Manager of Arthur Andersen’s Treasury Tax Solutions Group, focuses on the case of a UK multinational with European subsidiaries participating in Euro cash pooling with the pool header account held by a UK company in the UK.

As a more general checklist, the main legal issues that require consideration in establishing a global cash management arrangement, include: Exchange control rules, e.g. reporting requirements. Bank account restrictions, e.g. can local accounts be..

In this issue FITAR presents a comprehensive study of the tax issues arising from international cash management. In this first article, Stuart Porter, Senior Tax Manager of PricewaterhouseCoopers’ Banking & Capital Markets team, provides a detailed review of the various tax exposures impacting global cash management arrangements that may be encountered by the multinational corporation.

It is by no means the case that the label attached to a transaction will always determine its tax treatment. Stephen Edge of Slaughter and May examines the Ensign principle and reminds the tax adviser that one of his or her most important tasks is to establish the critical difference in terms of legal analysis or legal relationship between one transaction and another and to make sure that it survives all the stages of documenting a deal.

Last month Roger Muray of Ernst and Young explained the background to the amendments that the Inland Revenue is proposing to the foreign exchange (forex) local currency provisions. In this article, John Lindsay reviews the “fine print” of the draft amendments that the Inland Revenue published for consultation in early February.