Table of Contents

• Introduction
• Summary of the book
• CHAPTER 1: The bail out – from hero to villain
• The media feeding frenzy
• Other side of the Atlantic
• US Senate “Tax Dodge” Report
• CHAPTER 2: Tax authorities intervention
• USA borrower
• Substance v Form
• Worldwide taxation and tax credits
• Securities Lending and Repo
• Taxpayers file lawsuits in the US claiming tax refunds
• US docketed cases
• Who owns the public transport system?
• CHAPTER 3: Structured finance
• The ‘art’ of tax avoidance
• Blowing the whistle
• Regulators and tax arbitrage
• When the herd moves in
• The spirit of the law
• GAAR
• Differing approaches
• Impact of European jurisprudence
• Are tax havens to blame?
• CHAPTER 4: The role of jurisdictional competition in tax avoidance arbitrage
• Uncut
• Going Dutch
• Consumer choice
• Entity classification for tax purposes
• Every taxpayer’s dream (or not)
• When the taxman calleth
• CHAPTER 5: Jurisdictional case review
• THE UK
• ITALY
• FRANCE
• NEW ZEALAND
• AUSTRALIA
• UNITED STATES
• SOUTH AFRICA
• Concluding remarks
• Epilogue
• Appendix 1: Jurisdictional Arbitrage Financing Transaction
• Appendix 2: A Code of Practice on Taxation for Banks
• Appendix 3: Supplementary Guidance Note

About the Author

Nigel Feetham is a partner at Hassans International Law Firm. His area of practice includes insurance, funds and structured finance. He has played a major part in some of the most significant developments in the Gibraltar finance sector.