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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


UK South Africa double tax treaty - new protocol being introduced
  • Landwell
  • South Africa, United Kingdom
  • November 22 2011

South Africa is changing its system of taxing dividends paid to non-residents and introducing withholding tax (WHT


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 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 with Panama enters into force
  • Landwell
  • Luxembourg, Panama
  • November 22 2011

The Double Tax Treaty between Luxembourg and Panama has been ratifi ed and has entered into force


IRS emphasis on partnership audits
  • Landwell
  • USA
  • November 22 2011

Information published by the IRS shows a major change in the types of tax returns companies are fi ling due to changes in their business structures


Ireland United Arab Emirates - Double Tax Treaty
  • Landwell
  • Ireland, United Arab Emirates
  • November 22 2011

The United Arab Emirates - Ireland Double Tax Treaty, which was signed on July 1, 2010, has been ratified


Spain treaty updates
  • Landwell
  • Spain
  • November 22 2011

The tax treaty that Spain signed with Panama in Madrid on October 7, 2010, entered into force on July 25, 2011


Temporary reestablishment of the wealth tax
  • Landwell
  • Spain
  • November 22 2011

On September 6, Spain enacted Royal Decree- Law 132011 re-establishing temporarily the wealth tax, which has not been levied since 2007