International Tax Aspects Of Sovereign Wealth Investors
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| Author | : Richard Snoeij |
| Publisher | : Kluwer Law International B.V. |
| Total Pages | : 277 |
| Release | : 2018-04-18 |
| Genre | : Law |
| ISBN | : 9041194339 |
An increasing number of States have entered the market looking to invest resources in foreign assets. This emergence of States acting as investors, managing the wealth of a nation and competing in the marketplace with private investors, has attracted growing and wide attention. This book is the first in-depth analysis of the international tax aspects of sovereign wealth investors, and serves as a comprehensive guide to designing tax policy, from a source State perspective, toward inbound sovereign wealth investment. Drawing on a wide range of relevant sources, including international instruments, domestic tax legislation, administrative practice, (international) case law and the writings of highly qualified publicists, the author fully addresses the following aspects of the subject: – the definition, functions, legal form, governance, home State tax status, etc. of sovereign wealth investors; – tax policy considerations and objectives (i.e., neutrality, equity and international attractiveness) from a source State perspective vis-à-vis foreign sovereign wealth investors; and – the potential impact of the sovereign immunity principle, bilateral tax treaties and European (Union) law on source States’ ability to achieve these tax policy objectives in relation to foreign sovereign wealth investors. The conceptual framework developed by the author will greatly assist source States in introducing new tax policy or in evaluating or reconsidering their existing tax policy vis-à-vis foreign sovereign wealth investors. In addition, practitioners, academics and (home States of) sovereign wealth investors will welcome this first authoritative analysis of an important but insufficiently understood subject in international tax.
| Author | : Leonard Schneidman |
| Publisher | : |
| Total Pages | : 0 |
| Release | : 2010 |
| Genre | : Investments, Foreign |
| ISBN | : 9781402414817 |
In Sovereign Wealth Funds, noted international tax lawyer Leonard Schneidman has assembled an array of essays, authored by a global collection of subject area experts, designed to explore three key aspects of SWFs: their regulation and governance, investment behavior, and taxation. You'll quickly discover this work to be the highly useful tool you and your clients need to assess the SWF phenomenon and its practical legal, tax and financial implications.
| Author | : Harold Kent Baker |
| Publisher | : Springer Nature |
| Total Pages | : 677 |
| Release | : 2024 |
| Genre | : Sovereign wealth funds |
| ISBN | : 3031508211 |
The Palgrave Handbook of Sovereign Wealth Funds provides a comprehensive, detailed analysis of these funds from a multidimensional perspective consisting of 33 chapters divided into seven sections. Section I provides background material about SWFs, providing a foundation for the remainder of the handbook. Section II examines various controversies, governance, and accountability topics involving SWFs. Section III discusses the political, legal, and tax aspects of SWFs. Section IV reviews numerous topics involving SWF management. Section V deals with SWFs' policies, preferences, and performance. Section VI provides descriptive analyses of SWFs based on country or region. It also offers a comparison of SWF similarities and differences across countries. Section VII concludes by examining special issues and the future of SWFs. This handbook spans the gamut from theoretical to practical while offering the right balance of detailed and user-friendly coverage. Discussion of relevant research permeates the handbook. Although other books are available on SWFs, few are as comprehensive or provide a multidimensional perspective from academics and practitioners. This handbook fills a gap by showing how SWFs are a growing and dynamic force in international finance.
| Author | : Victor Fleischer |
| Publisher | : |
| Total Pages | : 74 |
| Release | : 2008 |
| Genre | : |
| ISBN | : |
Sovereign wealth funds enjoy an exemption from tax under section 892 of the tax code. This anachronistic provision offers an unconditional tax exemption when a foreign sovereign earns income from non-commercial activities in the United States. The provision, which was first enacted in 1917, reflects an expansive view of the international law doctrine of sovereign immunity that the United States (and other countries) discarded fifty years ago in other contexts. The Treasury regulations accompanying section 892 define non-commercial activity broadly, encompassing both traditional portfolio investing and more aggressive, strategic equity investments. Because section 892 was not written with sovereign wealth funds in mind, the policy rationale for this generous tax treatment has not been closely examined before. This Article provides a framework for analyzing the taxation of sovereign wealth. I start from a baseline norm of quot;sovereign tax neutrality,quot; which would treat the investment income of foreign sovereigns no better and no worse than private investors' income. Nor would it favor any specific nation over another. Whether we should depart from this norm depends on several factors, including the external costs and benefits created by sovereign wealth investment, whether tax or other regulatory instruments are superior methods of attracting investment or addressing harms, and which domestic political institutions are best suited to implement foreign policy. I then consider whether we should impose an excise tax that would discourage sovereign wealth fund investments in the equity of U.S. companies. If desired, the tax could be designed to complement nontax economic and foreign policy goals by discouraging investments by funds that fail to comply with best practices for transparency and accountability.The case for repealing the existing tax subsidy is strong. We should tax sovereign wealth funds as if they were private foreign corporations; there is no compelling reason to subsidize sovereign wealth. My analysis also shows that imposing a special excise tax may not be the optimal regulatory instrument for managing the special risks posed by sovereign wealth funds, although a carefully-designed tax would be more effective than the status quo.
| Author | : Fabio Bassan |
| Publisher | : Edward Elgar Publishing |
| Total Pages | : 453 |
| Release | : 2015-06-29 |
| Genre | : Law |
| ISBN | : 1781955204 |
Research on the role of sovereign investments in a time of crisis is still unsatisfactory. This Research Handbook illustrates the state of the art of the legal investigation on sovereign investments, filling necessary gaps in previous research. Current
| Author | : |
| Publisher | : |
| Total Pages | : 129 |
| Release | : 2008 |
| Genre | : Investments, Foreign |
| ISBN | : |
| Author | : Douglas Cumming |
| Publisher | : Oxford University Press |
| Total Pages | : 737 |
| Release | : 2017 |
| Genre | : Business & Economics |
| ISBN | : 0198754809 |
Sovereign Wealth Funds have become increasingly powerful and influential investors. Their increasing role, and unusual character as both political and market actors, raise a number of issues with regard to finance, politics, regulation, and international business. This handbook draws together the growing but fragmented research on SWFs.
| Author | : U.S.-China Economic and Security Review Commission |
| Publisher | : |
| Total Pages | : 156 |
| Release | : 2008-02-07 |
| Genre | : |
| ISBN | : 9781477490266 |
Government ownership of large investment funds, known as sovereign wealth funds, is not new, but it is a markedly growing trend that raises important issues for policymakers to consider. The world's sovereign wealth funds (estimated to hold $2.5 trillion in assets) are significantly larger than all of the world's hedge funds combined. According to some estimates, sovereign wealth funds could grow to hold as much as $12 trillion over the next eight years. The Abu Dhabi Investment Authority, Norway's Government Pension Fund, and Saudi Arabia's wealth fund, according to IMF estimates, each currently have more than a quarter of a trillion dollars in assets to invest. Kuwait, Singapore, Russia, and Hong Kong also each have sovereign wealth funds totaling more than $100 billion in assets. Focusing specifically on China, the Chinese government recently established the China Investment Corporation, with assets estimated at $200 billion. This new Chinese government fund appears to be taking a measured approach to its investments and is acting as a passive investor.
| Author | : Mindy Herzfeld |
| Publisher | : Kluwer Law International B.V. |
| Total Pages | : 435 |
| Release | : 2022-10-11 |
| Genre | : Law |
| ISBN | : 9403528915 |
Structuring Cross-Border Transactions: U.S. Tax Considerations The U.S. international tax provisions that impact cross-border transactions are far-reaching. In recent years, the rules have become more complex, less systematic, and more difficult to make sense of. In this helpful book, a well-known author and practitioner demystifies many of the structuring questions implicated in inbound and outbound cross-border investments, acquisitions, and joint ventures, exposing traps and planning opportunities and showing how the rules really operate in specific fact patterns. All key aspects of structuring a cross-border transaction are analyzed, including: anti-deferral regimes (subpart F and global intangible low-taxed income (GILTI)); how check-the-box (CTB) regulations can maximize tax benefits and minimize tax inefficiencies; how the indirect foreign tax credit provides opportunities for tax beneficial planning; U.S. tax-free reorganization rules as they apply in the cross-border area; U.S. anti-inversion rules that affect cross-border deals; effect of anti-hybrid rules; concerns of particular classes of investors that will influence the form of a transaction; and typical points of friction between buyers and sellers in the cross-border context. Detailed examples, with financial metrics included, help guide decision making at every step and assist in the understanding of key drivers materially impacting results. Treaty considerations and implications are discussed throughout. This book fills a big gap in the tax literature by providing a guide for practitioners from any country who need to understand the U.S. tax consequences of a particular transaction. Its focus on how U.S. tax law affects the ways in which transactions are put together in the real world, and its in-depth analysis of how U.S. tax provisions interrelate and interact with foreign tax rules will prove of immeasurable value to corporate lawyers, finance professionals, and others active in cross-border mergers and acquisitions. It will become an indispensable reference tool for transactional tax practitioners.
| Author | : Richard Snoeij |
| Publisher | : |
| Total Pages | : 0 |
| Release | : 2023 |
| Genre | : |
| ISBN | : |
Cross-border investments of states have rapidly increased over the last few years and are, more often than not, structured through special purpose investment funds or arrangements, known as sovereign wealth funds (SWFs). The total value of assets under the management of SWFs is currently estimated at USD 7.1 trillion (as at March 2016). In relation to states, their subdivisions and their wholly owned entities, the OECD Commentary mentions the customary international law principle of sovereign immunity. According to this principle, a foreign sovereign state can be held immune from the jurisdiction of the courts of another sovereign state in civil proceedings (jurisdictional immunity), and this principle may also apply to state-owned entities. A number of states, including Australia, Canada, the United Kingdom and the United States, apply the sovereign immunity principle to taxation as well. SWFs might also benefit from these tax immunities. The preferential tax treatment over other (private) investors to which a tax immunity regime potentially gives rise has historically been explained (or justified) by reference to the sovereign immunity principle as a principle of customary international law. However, an examination of the tax immunity regimes and the rules on jurisdictional immunity in all four states strongly suggests that the tax exemptions accorded to foreign sovereigns and SWFs are not (or, at least, are no longer) truly motivated by sovereign immunity. As a result, these states, and other states in which a comparable situation exists, would need to re-evaluate their existing tax immunity framework.Full-text Paper.
