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IRS increases scrutiny of inter-company debt arrangements

USA - October 17 2011 The IRS has always been concerned with issues of thin capitalization, debt versus equity characterization and interest deductibility.

Bernard Gainnier, Renaud Jouffroy.

The latest interpretation of the Technical Service Fees article under relevant Double Tax Treaties concluded by China

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.

Renaud Jouffroy.

Critical IRS policy change regarding processing and filing deadline to carryback 2010 net operating losses

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.

Bernard Gainnier, Renaud Jouffroy.

Portugal / Luxembourg Double Tax Treaty

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.

Renaud Jouffroy.

UK / South Africa double tax treaty - new protocol being introduced

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).

Bernard Gainnier, Renaud Jouffroy.