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A&L Goodbody | Ireland | 8 Feb 2021

Ireland’s implementation of the ATAD interest limitation rule 2021

The Department of Finance published a Feedback Statement in relation to the ATAD Interest Limitation rules (ILR) in December 2020. Ireland is…
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Indochine Counsel | Vietnam | 28 Aug 2020

New Tax Treatment of Loan Interest Expenses

On 24 June 2020, the Government promulgated Decree No. 68/2020/ND-CP ("Decree 68") amending Article 8.3 of Decree No. 20/2017/ND-CP dated 24 February…
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Blue J Legal | USA | 5 Jul 2019

What the TCJA means for tax exempt organisations

Benjamin Alarie outlines the implications of the Tax Cuts and Jobs Act for tax-exempt taxpayers.
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Cliffe Dekker Hofmeyr | South Africa | 12 Apr 2019

Domestic treasury management companies – alignment of tax and exchange control provisions

When the domestic treasury management company (DTMC) regime came into effect in 2013, a 'DTMC' was defined in the Income Tax Act as a company that is incorporated or deemed to be incorporated in South Africa. The 2019 Budget explains that in 2017 the Income Tax Act was amended to remove this requirement, which conflicts with the South African Reserve Bank's requirements, prompting calls for......
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McDermott Will & Emery | USA | 11 Apr 2019

Tax Court Rules State Corporate Incentives Are NOT Taxable Income Under Federal Law

Many states and localities give incentives for business to move or transact in their locations. There has always been a question of whether these…
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Cliffe Dekker Hofmeyr | South Africa | 5 Apr 2019

Controlled foreign company comparable tax threshold to be decreased

The 2019 Budget noted that a global downward trend in corporate taxation rates may lead to an unintended increase in the imputation of the net income of controlled foreign companies (CFCs) in South African shareholders' taxable income. This could occur despite the fact that at its inception, a CFC has operated in a jurisdiction with tax rates which met the threshold contained in the Income......
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McMillan LLP | Canada | 3 Apr 2019

Budget 2019: CRA Refines Mutual Fund Allocation to Redeemers Methodology and Tightens Rules on TFSAs

Budget 2019, released on March 19, 2019, proposes new rules to combat tax strategies perceived by the Government to be employed by certain mutual…
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Eversheds Sutherland (US) LLP | USA | 1 Apr 2019

Maryland Tax Court Strikes Again: Out-of-State LLCs Liable for Maryland Income Tax

The Maryland Tax Court held that six nonresident Limited Liability Companies (LLCs) wholly-owned by another out-of-state limited liability company…
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Cliffe Dekker Hofmeyr | South Africa | 29 Mar 2019

Deducting interest for debt incurred during acquisition of shares

It has always been a contentious issue whether a purchaser of shares can claim a deduction for the interest that it incurs on monies borrowed to acquire the shares. The legislature intervened by introducing Section 240 of the Income Tax Act, which allows purchasers to deduct interest for a debt that is used to fund the acquisition of shares in certain circumstances. However, the target must......
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VdA | Australia, China, Portugal | 26 Mar 2019

Tonnage tax special regime & new ships registration framework

Order 72-B/2019, of 4 March 2019, sets forth the taxable income reduction mechanism applicable to Portuguese-based shipping companies, following the…
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