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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

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

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

Tax deductibility of G&A expenses allocated by offshore parent company

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

Despite Taiwan tax regulations expressly providing that general and administrative ("G&A") expenses of a foreign head office may be allocated to its Taiwan branch based on various criteria, the tax office often challenges the adequacy of such allocations if the required supporting documentation is not in place or the foreign parent company is merely a paper company

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

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

Deduction on dividends received - abolishment of fixed financial asset condition

  • Landwell
  • -
  • Belgium
  • -
  • April 27 2011

Under Belgian corporate income tax law, Belgian taxpayers can, under conditions, benefit from a 95 deduction on dividends received ( DRD

Commitment to tax rate at 12.5

  • Landwell
  • -
  • Ireland
  • -
  • April 27 2011

Following the recent Irish election, and despite the large amount of press coverage, the new Prime Minister of Ireland has recently reaffirmed with other leaders in the European Union the new Government's commitment to the 12.5 corporation tax rate

Germany-Hungary

  • Landwell
  • -
  • Germany, Hungary
  • -
  • April 27 2011

On February 28, 2011, Germany and Hungary signed a revised agreement (Revisionsabkommen

Germany-Cyprus

  • Landwell
  • -
  • Cyprus, Germany
  • -
  • April 27 2011

Germany signed a new Double Tax Treaty with Cyprus on February 18, 2011