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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

Double tax treaty - Armenia Ireland

  • Landwell
  • -
  • Armenia, Ireland
  • -
  • October 17 2011

Ireland signed a double tax treaty with Armenia on July 14, 2011

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

Portugal Luxembourg Double Tax Treaty

  • Landwell
  • -
  • Luxembourg, Portugal
  • -
  • April 27 2011

On February 24, 2011, the Portuguese Council of Ministers approved the proposal of a resolution that approves the protocol amending the DTT signed between Portugal and Luxembourg

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

Temporary reestablishment of the wealth tax

  • Landwell
  • -
  • Spain
  • -
  • November 22 2011

On September 6, Spain enacted Royal Decree- Law 132011 re-establishing temporarily the wealth tax, which has not been levied since 2007

Portugal Cayman Islands Tax Information Exchange Agreement

  • Landwell
  • -
  • Cayman Islands, Portugal
  • -
  • April 27 2011

On February 28, 2011 the Portuguese President ratifi ed the Tax Information Exchange Agreement signed between Portugal and the Cayman Islands on May 13, 2010

Double tax treaties

  • Landwell
  • -
  • Hong Kong, Kuwait, Norway, Portugal, Uruguay
  • -
  • May 20 2011

On April 5, 2011, the Portuguese President ratified the Double Tax Treaty signed between Portugal and Uruguay on November 30, 2009