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Results: 1-10 of 99

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

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

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

US tax treaty developments

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

The Senate Foreign Relations Committee on July 26, 2011 approved the new US-Hungary tax treaty and protocols to the Luxembourg and Switzerland treaties, with the recommendation that all three pacts be approved

OECD’s peer review report

  • Landwell
  • -
  • Luxembourg
  • -
  • October 17 2011

On September 12, 2011, the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes published its peer review report in relation to Luxembourg

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