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Results: 1-10 of 101

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


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


Double Tax Treaty with Barbados enters into force
  • Landwell
  • Luxembourg, Barbados
  • November 22 2011

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


NlPanama tax treaty
  • Landwell
  • Panama, Netherlands
  • November 22 2011

The tax treaty that the Netherlands signed with Panama on October 6, 2010 has been sent to the House of Representatives


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


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


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


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