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Derivatives & Financial Instruments
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Issue No. 5 (2006) of the
Derivatives & Financial Instruments is now available online.
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Number 5 - 2006 contains the following:
 

ARTICLES

United States

Section 1248 Proposed Regulations: Cleaning in Dark Corners
Kevin M. Cunningham
pp. 215-222
This article provides a thorough and comprehensive analysis of the recently issued proposed regulations to Sec. 1248 of the IRC concerning recharacterization of certain US person’s gains on the sale of certain foreign corporations as dividend income to the extent of the earnings attributable to the shares sold.
Denmark

Private Equity Funds and Leveraged Buyouts: Attack on Transparent Entities and Other Controlling Entities

Jakob Bundgaard

pp. 223-230

This article provides a comprehensive overview of the Danish tax issues connected to the financing of the private equity funds, with particularly focus on debt financing. The background of the applicable Danish tax rules and some recent regulatory developments are analysed.

International

Securitization, Capital Adequacy and the Impact of IFRS, FASB 140 and FIN 46R

Anton Joseph

pp. 231-235

This article provides an in-depth analysis of the Prudential Standards applicable to authorized deposit-taking institutions and focuses on banks and other financial institutions transferring assets to special purpose vehicles in the process of securitization, and on the interaction with IAS 39.

COMPARATIVE SURVEY

Tax Treatment of Weather Derivatives

France

Sophie Marciniak

pp. 236-240
Italy
Paola Flora
pp. 241-245

RECENT DEVELOPMENTS

Australia

Ruling Denies Capital Gains Tax Discount

Anton Joseph
pp. 246-251
Netherlands

The 2007 Tax Overhaul: Making the Netherlands More Appealing

Paul J.M. Bruin and Diederik G.A. Meijer

pp. 252-253

The primary goal of a bill titled Working on Profit submitted by the State Secretary for Finance on 24 May 2006 is to put the Netherlands back on the shortlist of jurisdictions that are attractive for the international business world to invest in. "How is this done?", you may ask. The answer to this question is found in a number of profound changes to the tax law, which are described in this article.

CUMULATIVE INDEX

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