We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
In cooperation with Association of Corporate Counsel
  Request new password

Search results

Order by most recent / most popular / relevance

Results: 1-10 of 99

IRS increases scrutiny of inter-company debt arrangements

  • Landwell
  • -
  • USA
  • -
  • October 17 2011

The IRS has always been concerned with issues of thin capitalization, debt versus equity characterization and interest deductibility

The latest interpretation of the Technical Service Fees article under relevant Double Tax Treaties concluded by China

  • Landwell
  • -
  • China, India, Pakistan, United Kingdom
  • -
  • May 20 2011

There are a few Double Tax Treaties ("DTTs") concluded by China, namely the DTTs with UK, India and Pakistan (referred as "relevant DTTs" hereafter), which include a specific article on Technical Service Fees

Critical IRS policy change regarding processing and filing deadline to carryback 2010 net operating losses

  • Landwell
  • -
  • USA
  • -
  • November 22 2011

The ability for corporate taxpayers to obtain a quick refund by filing IRS Form 1139, Corporation Application for Tentative Refund, is important and can quickly increase a corporation’s cash flow in today’s difficult economy

Report of Foreign Bank and Financial Accounts “FBAR” new rules expand the number of officers and employees required to file by June 30, 2011

  • Landwell
  • -
  • USA
  • -
  • May 20 2011

New regulations effective March 29, 2011, can affect a significant number of US persons with a financial interest in, or signature authority over, foreign financial accounts reported on the Form TD F 90-22, Report of Foreign Bank and Financial Accounts, commonly referred to as FBAR

Draft Assessment Rule for Thin Capitalization

  • Landwell
  • -
  • Taiwan
  • -
  • May 20 2011

The "thin capitalization rule" was introduced in an amendment to the Taiwan Income Tax Act ("ITA") in January 2011

Update on double tax treaties

  • Landwell
  • -
  • Singapore, Uzbekistan
  • -
  • November 22 2011

The protocol to the treaty with Uzbekistan, which incorporates the internationally agreed Standard for the Exchange of Information (EOI) into the treaty, has been ratified and will take effect from November 1, 2011

Treaty update

  • Landwell
  • -
  • Hong Kong
  • -
  • April 27 2011

A new DTT with Hong Kong, signed on June 22, 2010, came into force on February 10, 2011 and will be effective from January 1, 2012

Double Tax Treaty with Barbados enters into force

  • Landwell
  • -
  • Barbados, Luxembourg
  • -
  • November 22 2011

The Double Tax Treaty between Luxembourg and Barbados has been ratified and has entered into force

Portugal East Timor double tax treaty

  • Landwell
  • -
  • Portugal
  • -
  • November 22 2011

On September 27, it was announced that negotiations have been initiated between the Portuguese Government and the authorities of East Timor towards the signature of a Double Taxation Treaty

UK Mauritius double tax treaty - new protocol being introduced

  • Landwell
  • -
  • Mauritius, United Kingdom
  • -
  • November 22 2011

A new protocol introduces an exchange of information clause to this treaty