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PwC Legal | USA | 30 Mar 2017

Tax accounting considerations of recent U.S. tax reform proposals

President Trump and the Republican-controlled Congress have indicated that comprehensive tax reform is currently one of the federal government's top


Baker McKenzie | Spain | 31 Aug 2016

Is default interest deductible from Corporate Income Tax?

Whether default interest following verification or inspection procedures is deductible depends on the fiscal year under inspection and the date when


Baker McKenzie | USA, France | 30 Jun 2016

Debt waiver granted to a foreign subsidiary: the characterization of the transaction in the beneficiary's state does not matter (Versailles Administrative Court of Appeal, Jan. 28, 2016, No. 13VE00986)

In its decision dated January 28, 2016, the Administrative Court of Appeal of Versailles provided some interesting details about the consequences of


Herzog Fox & Neeman | Israel | 30 Dec 2015

Important Court Ruling - Inclusion of Equity Based Compensation in Cost Plus Arrangements

This is an important update for any company that is a party to an inter-group services transaction and is applying a cost-plus transfer pricing


CMS, China | China | 30 May 2014

Chinese tax regulation update

In this regulation, the SAT clarifies several issues related to CIT calculation. The following main points shall be noted: CIT treatment for assets


Chapman Tripp | New Zealand | 15 May 2014

Southern Man delivers Speights ad budget

Budget 2014 has Bill English's Speights-style "Southern Man" brand written all over it. It is prudent, pragmatic, steady, unexcitable. English can


Porter Wright Morris & Arthur LLP | USA | 26 Nov 2013

IRS limits ability to deduct annual bonus payments in the year of accrual, rather than the year paid

Are you able to accrue and deduct annual bonuses for a 2013 calendar year performance period in 2013, so long as you pay the bonuses to your


RPC | United Kingdom | 26 Apr 2013

Tribunal rejects purposive interpretation and allows taxpayer's appeal

The First-tier Tribunal ('FTT') has held in Fidex Ltd v HMRC,1 that a loan relationship debit should not be disallowed under paragraph 13, Schedule 9


Eversheds Sutherland (US) LLP | USA | 2 Aug 2012

Bringing certainty to an uncertain tax position: IRS LB&I directive addresses partial worthlessness deductions claimed by insurance companies

On July 30, 2012, the IRS Large Business & International (LB&I) Division issued guidelines intended to reduce the controversy associated with partial worthlessness deductions claimed by insurance companies.


Williams Mullen | USA | 29 Feb 2012

White House proposal for Business Tax Reform

On February 22, 2012, the Obama administration issued The President’s Framework for Business Tax Reform, an outline for what would be the first major overhaul of the U.S. Tax Code since 1986.

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