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1	Conduit Companies, Beneficial Ownership, and the Test of Substantive Business Activity in Claims for Relief under Double Tax Treaties Jain, Saurabh, Prebble, John, Bunting, Christina January 2014 (has links) (PDF) If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is no more than a congeries of arrangements that represents the people behind it. Faced with these contradictory considerations, people have adopted surrogate tests that they attempt to employ in place of the treaty test of beneficial ownership. An example is that treaty benefits should be limited to companies that are both resident in the states that are parties to the treaty and that carry on substantive business activity. The test is inherently illogical. The origins of the substantive business activity test appear to lie in analogies drawn with straw company and base company cases. Because there is no necessary relationship between ownership and activity, the test of substantive business activity can never provide a coherent surrogate for the test of beneficial ownership. The article finishes with a Coda that summarises suggestions for reform to be made in work that is to follow. (authors' abstract) / Series: WU International Taxation Research Paper Series RVK QL 530, PP 8080
2	Semi-analytische und simulative Kreditrisikomessung synthetischer Collateralized Debt Obligations bei heterogenen Referenzportfolios / Unternehmenswertorientierte Modellentwicklung und transaktionsbezogene Modellanwendungen / Semi-Analytical and Simulative Credit Risk Measurement of Synthetic Collateralized Debt Obligations with Heterogeneous Reference Portfolios / A Modified Asset-Value Model and Transaction-Based Model Applications Jortzik, Stephan 03 March 2006 (has links) No description available. 330 Wirtschaft Economic Sciences Asset-Backed-Securities CDO CBO CLO ABS Zweckgesellschaft Zinsunterbeteiligung PROMISE KfW Banken Replenishment Unternehmenswertmodell Reduziertes Modell Zeittransformation Brownsche Brücke Ausfallschranke Fourier-Transformation Faktormodell Ausfallrisiko Kreditrisiko Risikoprämie Ratingmigration Asset-Backed Securities CDO CBO CLO ABS Special-Purpose Vehicle Interest Subparticipation PROMISE KfW Banks Replenishment Asset-Value Model Reduced-Form Model Time Transformation Brownian Bridge Default Barrier Fourier Transformation Factor Model Default Risk Credit Risk Risk Premium Rating Migration 85.30 EJBB 280: Finance portfolios investment {Mathematical economics} EJBB 300: Risk theory insurance {Mathematical economics} LCC100

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Conduit Companies, Beneficial Ownership, and the Test of Substantive Business Activity in Claims for Relief under Double Tax Treaties