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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

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

Tax-free merger - notional interest deduction

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

Recently, an advance ruling has been published by the Belgian Ruling Commission confirming the view of the Belgian Minister of Finance that, in the envisaged tax-free merger, the notional interest deduction possibilities of the acquired company remained unchanged in the hands of the acquiring company

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

ECJ decides on Portuguese legislation on nonresident pension funds taxation

  • Landwell
  • -
  • European Union, Portugal
  • -
  • November 22 2011

On October 6, the European Court Of Justice (ECJ), issued its decision on the procedure brought forward on December 1, 2009 by the European Commission (EC) against the Portuguese Republic (Case C-49309

Cost plus method by PE for R&D is at arm’s length

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

The Belgian Ruling Commission published an advance ruling on the application of a cost plus method by a Belgian PE carrying out a limited R&D activity in Belgium for group companies

Interim measure for currency exchange gains and losses on participations announced in the Netherlands

  • Landwell
  • -
  • Netherlands
  • -
  • May 20 2011

On April 8, 2011 the Dutch council of ministers approved a measure proposed by the Dutch State Secretary of Finance regarding the tax treatment of currency exchange fluctuations on participations in subsidiaries

Double tax treaty - Armenia Ireland

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

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

President Obama proposes $467 billion in tax increases to offset cost of jobs bill

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

President Barack Obama on September 12, 2011 sent to Congress legislative language and analysis for the $447 billion American Jobs Act that he proposed the week earlier, asking Congress to adopt the $467 billion in revenue raisers that would more than offset the cost of the package