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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


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

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


Protocol signed amending the DTA between China and Latvia
  • Landwell
  • China, Latvia
  • November 22 2011

A protocol amending the Agreement between the Government of the Public Latvia and the Government of the People’s Republic of China for the Avoidance of Double Taxation (DTA) and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital was concluded on August 24, 2011 and will enter into force after the completion of ratifi cation and notifi cation by both countries


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 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


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


President Obama proposes $1.5 trillion in new taxes and calls for comprehensive tax reform
  • Landwell
  • USA
  • October 17 2011

On September 19, 2011 the Obama Administration released The President’s Plan for Economic Growth and Defi cit Reduction, which proposes a 10-year, $3.6 trillion defi cit reduction plan that includes several international and other business tax increases


Senators Hagan and McCain introduce Foreign Earnings Reinvestment Act
  • Landwell
  • USA
  • October 17 2011

On October 6, 2011 Senators Kay Hagan and John McCain introduced a temporary dividend repatriation amendment to the job creation legislation the Senate is expected to address shortly


IRS memo provides insights into IRS thinking on use of Schedule UTP during exams
  • Landwell
  • USA
  • October 17 2011

A memorandum issued August 31, 2011 by Heather Maloy, Commissioner of the IRS’s Large Business & International Division to examination teams assigned to the Compliance Assurance Process Program, addresses examiners’ use of Schedule UTP, Uncertain Tax Position Statement


Double tax treaty - Armenia Ireland
  • Landwell
  • Armenia, Ireland
  • October 17 2011

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