BNA Tax Management an analogy can be made to the situation where a QBU changes its functionalcurrency. When a QBU changes from one functional currency to another, Regs. http://www.bnatax.com/tm/insights_currencytranslation.htm
Extractions: Subscribers Log-In Here Select a Tax Product to Log-In BNA Tax Management Library Portfolios Tax Practice State Tax Weekly Report Daily Tax Report Transfer Pricing Report Weekly State Tax Report Daily Report for Executives International Tax Monitor Payroll Administration Library TaxCore Search this site: Recent Developments Latest Top Tax Articles Federal Tax Highlights State Tax Highlights ... Quick Tax Reference State Quick Tax Reference Tax Calendar Useful Links Products Request for Free Trial ... By Philip D. Morrison, Esq. , Washington, D.C. A complete liquidation of a controlled foreign corporation ("CFC") subsidiary that qualifies under §332, of course, is a non-recognition event. Under §334(b)(2), the 80% corporate distributee takes a carryover basis for the property received in the liquidation. Often, the CFC will have a local currency (or other non-dollar) functional currency. When its property is distributed to its U.S. parent in complete liquidation, the basis of that property must be translated from the local currency to the functional currency (typically the U.S. dollar) of the parent. Oddly enough, there is no clear rule for how this translation is to be done. Translation could be done at the spot rate at the time of liquidation. This would result in no currency gain or loss being built in to the carried over basis. Alternatively, the translation could be done at the "historic" rate (the rate at the date of asset acquisition). This would result in a currency gain or loss (for the period between acquisition and liquidation) being reflected in the assets' bases. There are good arguments for either approach. A very brief summary of some of these arguments would include the following.
Continental Currency - Wikipedia, The Free Encyclopedia In 1723 Pennsylvania made its first issue of paper currency. It issued, in March,paper bills of credit to the amount of $60000, made them a legal tender in http://en.wikipedia.org/wiki/Continental_Currency
Extractions: USING CHINESE AND FOREIGN INVESTMENT SUBJECT: ACCOUNTANCY; FINANCE; FOREIGN EXCHANGE; JOINT-VENTURES ISSUING-DEPT: MINISTRY OF FINANCE ISSUE-DATE: 12/31/1987 IMPLEMENT-DATE: 12/31/1987 LENGTH: 762 words TEXT: 1. Fixed assets, intangible assets, othe rassets and raw materials acquired by and the costs and expenses thereof paid for by the joint venture with funds contributed by the parties to the joint venture as investment subscribed and denominated in a currency other than the renminbi (including investment subscribed and paid during the start-up period and investment subscribed and paid after operations have been started) may be recorded in renminbi at the book exchange rate. The same applies to fixed assets, intangible assets, other assets and raw materials acquired by the costs and expenses thereof paid for by the joint venture with funds from foreign currency loans. 3. Joint ventures engaged in foreign currency credit business shall record their foreign currency receipts and payments in separate accounts according to their currency denominateions. While preparing the period-end fiscal reports (accounting statements), the joint ventures shall record the period-end balances of all their foreign currency savings in banks and foreign currency receivable and payable accounts in renminbi using the prevailing exchange rates. The exchange gains and losses balance accrued from currency exchange transactions and transfer among various foreign exchange accounts within the current year shall be presented under the "Current Period Exchange Gains and Losses" item.
Extractions: ISSUING-DEPT: BANK OF CHINA ISSUE-DATE: 01/01/1983 IMPLEMENT-DATE: 01/01/1983 LENGTH: 2863 words TEXT: Bank of China Regulations For Foreign Currency Deposits (Category A) [Article 1] Deposits under these regulations are handled by the Banking Department of the Head Office of the Bank of China and the bank's domestic branches and sub-branches. [Article 2] An account for deposits may be opened by the following bodies, enterprises and organizations: (1) Foreign diplomatic, consular and commercial missions, organs of international bodies and offices of non-governmental organizations stationed in China; (2) Chinese and foreign enterprises and organizations set up in foreign countries or the Hong Kong and Macao regions; (3) Enterprises operating in China with overseas Chinese capital or foreign capital or joint Chinese and foreign capital;
Extractions: DYNAMITE CONSPIRACIES AND CURRENCY SPECULATION It is not my desire to ask for space in your paper for propagandist purposes. Recently in various quarters certain accusations have been made against the Anarchists into which other sections of socialists have been drawn, to which accusations I would ask the honor of a reply for the defence. Without further preliminary I will set to work to dispose of the accusation that a policy of violence is related to the philosophy of Anarchism or that it is resorted to in connection with the movement. In point of fact throughout the history of the movement with the exception probably of Caserio Santo and Le Breton (Camille Henry) the whole of the dynamite or allied affairs have had their origin in a single quarter, outside the Anarchist movement, no matter whether they occurred in France, England, Spain, America, or any other country, even to Australia ... His murder was alleged to be a disappointed office seeker but the murderers of Banquo in Shakespeare's Macbeth were people with real or supposed grievances against the victim, whilst Macbeth was the instigator of their crimes. I have left out many details which would make the narrative too long for this place, but the essential features are the foregoing; and this Chicago business is the key to the later accusations made against the Anarchists, it being the first case in which that sort of thing was charged to them ... The possible connection of this Chicago affair in its origin with the state of the American currency has been mentioned, and this will appear more probable as we proceed. It is well known that a central group of financiers, existing in Europe, carries its speculative operations all over the world, taking advantage of any temporary conditions which may embarrass the local capitalists. In relation to colonial loans, in Truth of August 1st, '03 I find this passage.
The Unofficial Paul Krugman Web Page And that s the problem when policy decisions are made on purely Here s whatI think will happen if and when China changes its currency policy, http://www.pkarchive.org/column/052005.html
Extractions: The Chinese Connection postCount('052005'); SYNOPSIS: Stories about the new Treasury report condemning China's currency policy probably had most readers going, "Huh?" Frankly, this is an issue that confuses professional economists, too. But let me try to explain what's going on. Over the last few years China, for its own reasons, has acted as an enabler both of U.S. fiscal irresponsibility and of a return to Nasdaq-style speculative mania, this time in the housing market. Now the U.S. government is finally admitting that there's a problem - but it's asserting that the problem is China's, not ours. And there's no sign that anyone in the administration has faced up to an unpleasant reality: the U.S. economy has become dependent on low-interest loans from China and other foreign governments, and it's likely to have major problems when those loans are no longer forthcoming. Here's how the U.S.-China economic relationship currently works: Money is pouring into China, both because of its rapidly rising trade surplus and because of investments by Western and Japanese companies. Normally, this inflow of funds would be self-correcting: both China's trade surplus and the foreign investment pouring in would push up the value of the yuan, China's currency, making China's exports less competitive and shrinking its trade surplus. But the Chinese government, unwilling to let that happen, has kept the yuan down by shipping the incoming funds right back out again, buying huge quantities of dollar assets - about $200 billion worth in 2004, and possibly as much as $300 billion worth this year. This is economically perverse: China, a poor country where capital is still scarce by Western standards, is lending vast sums at low interest rates to the United States.
Central Bank Kids - Student Centre It was not until 1951 that a regional currency with its own regulating board Thus , one Spanish silver dollar or eight Reales could be made into two http://www.centralbank.org.bb/centralkids/history.htm
Extractions: Money History The History of Coins and Currency In Barbados The story of money in Barbados contains many intriguing chapters which span three and a half centuries. For most of this period, the value of money depended on the Crowns authority. It was not until 1951 that a regional currency with its own regulating board was introduced. In 1972 Barbados assumed control of its monetary system and established the Central Bank of Barbados. Early settlement and the Barter System The first settlers in 1627 brought prevailing English monetary systems with them, but there was very little actual money in the island. For a long time cotton, tobacco and sugar were legal tender. It was forbidden to export coins from Britain, and the English would not permit the colonists to mint their own. As a result, a wide variety of Spanish and Portuguese colonial coins were circulated in the West Indies. However, complaints about the shortage of circulating money in the islands continued. In an effort to keep the existing coins in the island, the colonial government deliberately over-valued the coins in circulation. The values of these coins were fixed at an official rate from time to time. They were not finally withdrawn from use until 1893.
Paul Van Eeden's Weekly Column On Kitco If China does not allow its currency to appreciate against the dollar, and ifthe US goes While every attempt is made to avoid conflicts of interest, http://www.kitco.com/weekly/paulvaneeden/apr182005.html
Extractions: April 18, 2005 Central to the thesis that the gold price will continue to rise on the back of a falling US dollar, is the premise that China will forego its policy of supporting the dollar in favor of letting its own currency, the renminbi, appreciate. Both China and Japan are accumulating massive amounts of dollars as a result of their trade surpluses with the United States. But instead of selling those trade dollars into the foreign exchange markets, they, and other countries, are hoarding the dollars and investing them in US Treasury securities. As a result the US dollar is currently trading at a much higher exchange rate than it should versus the renminbi, the yen, other Southeast Asian currencies and, in fact, most currencies. Many people have argued that China will not allow the renminbi to appreciate against the dollar because it needs US consumption to drive its fledgling economy. But pressure is mounting from Europe, the United States, the World Bank and the IMF for China to let its currency appreciate.
New Iraqi Currency / New Iraqi Dinar The American Bank Note Company traces its beginning back to 1795, The newcurrency was made available to the Iraqi people on 15 October 2003. http://www.globalsecurity.org/military/world/iraq/currency-reform.htm
Extractions: var zflag_nid="224"; var zflag_cid="8/7/3/1"; var zflag_sid="1"; var zflag_width="728"; var zflag_height="90"; var zflag_sz="14"; var zflag_nid="224"; var zflag_cid="97/63/19/3/1"; var zflag_sid="1"; var zflag_width="120"; var zflag_height="600"; var zflag_sz="8"; Choose: HTML TEXT AOL var zflag_nid="224"; var zflag_cid="91/20/3/1"; var zflag_sid="1"; var zflag_width="300"; var zflag_height="250"; var zflag_sz="9"; var zflag_nid="224"; var zflag_cid="107/18/3/1"; var zflag_sid="1"; var zflag_width="160"; var zflag_height="600"; var zflag_sz="7"; Iraq has a cash driven society where banks are seldom viewed as places to store consumer wealth and communications between branches of even the same bank are often difficult to conduct and rely mostly on face-to-face meetings to update account balances rather than the use of automated networks. The flow of funds in Iraqs economy in general is more often than not, one of funds flowing out from banks with very little recirculation as is experienced in other societies. Why does this happen? Its a result of learned behavior including consumer experiences dating back to the end of the first Iran-Iraq war. During this timeframe, the former dictator found the country nearly broke and faced with making millions in stipend payments to returning soldiers. To generate cash, he instructed all banks to stop making payments other than those needed to pay government workers. Most who stored their wealth in the banking system lost everything. Accordingly, the current distrust in the banking system will take time and consumer education to overcome.
Extractions: Search Tips See also: Articles of Agreement of the International Monetary Fund Each member shall deal with the Fund only through its Treasury, central bank, stabilization fund, or other similar fiscal agency, and the Fund shall deal only with or through the same agencies. a ) Except as otherwise provided in this Agreement, transactions on the account of the Fund shall be limited to transactions for the purpose of supplying a member, on the initiative of such member, with special drawing rights or the currencies of other members from the general resources of the Fund, which shall be held in the General Resources Account, in exchange for the currency of the member desiring to make the purchase. b ) If requested, the Fund may decide to perform financial and technical services, including the administration of resources contributed by members, that are consistent with the purposes of the Fund. Operations involved in the performance of such financial services shall not be on the account of the Fund. Services under this subsection shall not impose any obligation on a member without its consent.
US Dollar Consolidates Its Gains | HSBC Currency Weekly The dollar consolidated its position as the currency of choice during the in the form of data and a confusing Fed report to consolidate its gains made . http://www.ameinfo.com/61130.html
Extractions: Tuesday, September 20 - 2005 Home E-mail User Login AME Info - Middle East Finance and Economy ... HSBC Currency Weekly Browse related articles Saturday, May 28 - 2005 at 12:53 The euro was forced to deal with a spate of problems associated with its political objectives as Germany called for early elections, whilst the French will be at the polls this weekend to vote on a referendum on the EU constitution. The dollar scored heavily as it climbed to fresh seven-month highs against the euro, Sterling and Swiss franc whilst yuan revaluation related talk kept the yen from losing further. The French vote is likely to be in focus whilst the release of key economic data from all major nations could see nerve-wracking moves in the week ahead.
US Dollar At Three-year Low | HSBC Currency Weekly At the beginning of the week the euro reversed losses it had made in the wake of Midway through the week the US currency continued its downward trend, http://www.ameinfo.com/29358.html
World Prout Assembly: Q&A: China Revalues Its Currency You will notice that efforts are being made to establish socalled societies in China has said it will link its currency to a basket of currencies, http://www.worldproutassembly.org/archives/2005/07/qa_china_revalu.html
Extractions: Put Economic Power in the Hands of the People! Moralists of the world - unite! "If we take the full meaning of the term society into consideration, it will be seen that till now human beings have not been able to form a real society. If India builds a society for only Indians, Pakistan for only Pakistanis, and England for only the English, then these three separate societies will exist, but we cannot look upon them as the society of humanity. Because humanity is divided into groups, one society will naturally try to thrive by exploiting the vitality of others. â¦You will notice that efforts are being made to establish so-called societies in some particular part of the world, for some particular section of the people, and based on some particular 'ism" or faith. A social consciousness based on such divisions lies latent in the minds of the people, whether they are Indian, Pakistani or English, so they remain absorbed in thoughts of their smaller groups." - Shrii Prabhat R. Sarkar Email Address : "Human beings have still not been able to form a human society, and have still not learned to move with the spirit of a pilgrim. Although many small groups, motivated by self-interest, work together in particular situations, not even a small fraction of their work is done with a broader social motive. By strict definition, shall we have to declare that each small family unit is a society in itself? If going ahead in mutual adjustment only out of narrow self-interest or momentary self-seeking is called society, then in such a society, no provision can be made for the disabled, the diseased or the helpless, because in most cases nobody can benefit from them in any way... in that case there always remains the possibility of some people getting isolated from the collective. All human beings must attach themselves to others by the common bond of love and march forward hand in hand; then only will I proclaim it a society." - Shrii Prabhat R. Sarkar
RGE - Nouriel Roubini S Blog Berlusconi is a sleazy crook who made his first financial fortunes by So, ifItaly could achieve a surgical real depreciation of its currency via a move http://www.roubiniglobal.com/
Petroleum Agreements (Currency Provisions) Act 1978 the amount of any borrowing made or any share capital received in foreigncurrency,. to meet its obligations to pay foreign currency during that period, http://www.paclii.org/pg/legis/consol_act/papa1978479/
Extractions: Home Databases WorldLII Search ... Feedback You are here: PacLII Databases Papua New Guinea Consolidated Legislation [Database Home Page] ... Help Petroleum Agreements (Currency Provisions) Act 1978 INDEPENDENT STATE OF PAPUA NEW GUINEA. Petroleum Agreements (Currency Provisions) Act style='font-style:normal'> 1978 Being an Act to give the force of law to certain provisions of certain agreements relating to petroleum. 1. Interpretation. In this Act, unless the contrary intention appears "the Agreement relating to PPL No. 17" means the agreement entered into on 25 July 1978 between the State, Australasian Petroleum Company Proprietary Limited and Niugini Gulf Oil Pty. Limited relating to Petroleum Prospecting Licence No. 17 (the area of which covers substantially the area of Permit No. 76); "the Agreement relating to PPL No. 18" means the agreement entered into on 25 July 1978 between the State, Australasian Petroleum Company Proprietary Limited, BP Petroleum Development Australia Pty. Limited and Niugini Gulf Oil Pty. Limited relating to Petroleum Prospecting Licence No. 18 (the area of which covers substantially the area of Permit No. 77). 2. Currency provisions to have the force of law.
Alder Capital: Currency Fund Managers currency Investments Managers Alder Capital use a systematic approach to to monitor transmissions made to and from its web site and may distribute, use, http://www.aldercapital.com/
Extractions: ENTER EXIT RISK DISCLOSURE STATEMENT THE RISK OF LOSS IN TRADING COMMODITIES CAN BE SUBSTANTIAL. YOU SHOULD THEREFORE CAREFULLY CONSIDER WHETHER SUCH TRADING IS SUITABLE FOR YOU IN LIGHT OF YOUR FINANCIAL CONDITION. THE HIGH DEGREE OF LEVERAGE THAT IS OFTEN OBTAINABLE IN COMMODITY TRADING CAN WORK AGAINST YOU AS WELL AS FOR YOU. THE USE OF LEVERAGE CAN LEAD TO LARGE LOSSES AS WELL AS GAINS. OTHER DISCLOSURE STATEMENTS ARE REQUIRED TO BE PROVIDED YOU BEFORE A COMMODITY ACCOUNT MAY BE OPENED FOR YOU. By virtue of your accessing, browsing or viewing these pages you have accepted the laws of Ireland as the law governing the operation and conduct of Alder Capital's web site. The courts of Ireland shall have exclusive jurisdiction over all claims or disputes arising in relation to, out of or in connection with the Alder Capital web site and its use.
US Prods China To Boost Its Currency For Fairer Trade - Global The word play was made last week by an official of the National China hasfixed or pegged its currency at about 8.28 yuan to the dollar since 1994. http://www.globalpolicy.org/socecon/crisis/2003/0728china.htm
Extractions: China's "yuan is wan." The word play was made last week by an official of the National Association of Manufacturers. The NAM is one of more than 80 trade groups urging Congress and the Bush administration to press China to revalue its currency so its goods are less competitive in the United States. A decade ago, the dollar value of the yuan on foreign-exchange markets would have been a minor issue in the US. China's economy just wasn't that important in the world picture. But China's enormous export success has made the yuan's price a hot issue today. "China is the world's greatest development story of the 21st century," declares Stephen Roach, chief economist at Morgan Stanley, a major New York investment banking firm. "Its emergence will not only benefit the 20 percent of the world that lives [there], but it will also benefit the 80 percent of us who do not." China's rapid economic growth - a fabulous 8 or 9 percent per year in real terms - has hung to a large degree on its roaring exports. In May, these had swelled to 37 percent above last year's levels. That, despite modest economic growth in the US, Europe, and Japan. A major recent problem for Europe is that as the dollar falls against the euro and the British pound, the value of the Chinese yuan for Europeans also declines - making Europe's competitive position even worse. China's export growth has brought howls of protest from the US business community. "In the last 18 months, we have really begun to hear from our members," says Frank Vargo, a NAM economist. "China cannot continue for too long ... to depend on a rising trade surplus with the US to continue fueling its economic growth." As for Europe, Donald Straszheim, an economic consultant in Santa Monica, Calif., predicts a bigger "outcry" over the next six to 12 months. China has fixed or "pegged" its currency at about 8.28 yuan to the dollar since 1994. Some say the yuan is now too cheap.
Currency Of course in this way, the exhaustion of its currency reserves is all too These payments could be made in gold as well as in ones own currency, http://www.gegenstandpunkt.com/english/currency.html
Extractions: The Competition of Nations for the Wealth of the World No one has any doubt that the exchange rate of currencies is of great importance national point of view of national accounts There are obvious advantages for assessing exchange rates from this point of view. Their way of looking at currency movements doesnt stoop to evaluate the state of the national currency as a mere condition for one or another private include the concerns of the business world in their calculations: they acknowledge success and failure in the fields of foreign trade and international credit as decisive factors of their own accounts, and consequently as relevant data for assessing the state of their currency. Conversely, they view their own budgetary conduct as a factor that affects the exchange rate as well as growth; whereas foreign exchange traders who on their part deal with the exchange rate as a factor in their calculations take the intimate association of finance ministers and central banks with money as grounds for holding them responsible for their difficulties. The commentaries published in the business section of a newspaper are not interested in the explanation consequences that these movements might have for the success of this or that economic interest. What passes for
Extractions: http://cnnfn.cnn.com/services/travelcenter/cityguide.htmll Tell each student to select three cities outside the United States. The site allows users to select individual cities within three groupings: Americas, Europe, and Asia/Africa. the amount of local currency After the student has found bus fares for three cities, he or she should go to the following cnnfn.com page:
Those Cross Currency Swaps Made A Profit - Opinion - Www.theage.com.au Those cross currency swaps made a profit. November 15, 2004 is now arguingthat the Commonwealth should have speculated its own currency and criticises http://www.theage.com.au/articles/2004/11/14/1100384424297.html?from=storylhs
