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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


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


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


Portugal Panama Double Tax Treaty
  • Landwell
  • Panama, Portugal
  • April 27 2011

On February 24, 2011, the Portuguese Council of Ministers approved the proposal of a resolution that approves the DTT signed between Portugal and Panama on August 27, 2010


Foreign company must file return for nontaxable taxable share transfer under treaty
  • Landwell
  • India, Netherlands
  • May 20 2011

The Authority for Advance Rulings ("AAR") recently ruled that a foreign company was required to file an India income tax return, even though no income was subject to tax in India as a result of an exemption under the India-Netherlands treaty


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


Draft proposals relating to withholding tax
  • Landwell
  • Canada
  • May 20 2011

The Department of Finance released draft legislation on March 16, 2011 that included a legislative response to a loss suffered by the Canada Revenue Agency at the Federal Court of Appeal


Finance Bill 2011 is enacted
  • Landwell
  • India
  • May 20 2011

India's Finance Bill, 2011, which was previously tabled and passed by both Houses of Parliament, received assent of the President of India on April 8, 2011 and is now enacted into law


Agreements for the Exchange of Information on Tax Matters
  • Landwell
  • Isle of Man, Portugal
  • May 20 2011

On March 21, 2011, the Portuguese President ratified the Agreement for the Exchange of Information on Tax Matters signed between Portugal and Isle of Man on July 9, 2010