Tax Efficient Foreign Exchange Management

JOHN F. CHOWN is the founder of JF Chown & Co., Ltd. and is also a Director of Fixed Income Research and Management, Ltd. An active writer and lecturer on taxation and international finance, he is coeditor of the Journal of Strategy in International Taxation and for many years was the contributer to the Financial Times, and to a regular column, Taxation and the Investor. Chown is co-founder and Executive Committee member of the Institute for Fiscal Studies, and also serves on the UK branch of the International Fiscal Association, the tax committee of the Institute of Directors and the technical committee of the Association of Corporate Treasures.

• Preface Managing Foreign Exchange Taxation The Problem Stated The Foreign Exchange Consequences of Trading Transactions The Economics of Exchange Risk Covering Longer-term Exposures Implicit Forward Exchange Rates The Tax Treatment of Interest Withholding Tax on Interest Modern Financial Instruments The United Kingdom The General Tax System The Tax Treatment of Interest Foreign Exchange Gains and Losses Financial Instruments The United States The General Implications of the US Tax Reform Act of 1986 The Tax Treatment of Interest Foreign Exchange Taxation US Case Law on Foreign Exchange Taxation Canada The General Tax System The Tax Treatment of Interest Taxation of Forex Gains and Losses Contintental Europe Continental Europe Interest Withholding Tax in the European Economic Community--A Current Dispute Australasia Australia New Zealand The Far East Japan Hong Kong and Singapore Bibliography Index