We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



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


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


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


Report on budgetary strategy
  • Landwell
  • Portugal
  • October 17 2011

Further to the Memorandum of Understanding concluded between the Portuguese Republic, the European Commission, the International Monetary Fund and the European Central Bank, the Portuguese Government announced its Report on Budgetary Strategy for the period 2011- 2015 on August 31, 2011


Extending tax deduction for purchase costs of intellectual property
  • Landwell
  • Hong Kong
  • May 20 2011

Currently, a tax deduction is available for the purchase costs of patent rights or rights to know-how


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


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


Discussion draft released for corporate rate reduction and territorial tax system
  • Landwell
  • USA
  • November 22 2011

On October 26, 2011, House Ways and Means Committee Chairman Dave Camp released for public comment a discussion draft on revenue-neutral corporate tax reform that lowers the top corporate tax rate to 25 and adopts a territorial tax system, generally effective for tax years beginning after 2012


2012 State Budget proposal
  • Landwell
  • Portugal
  • November 22 2011

On October 17, 2011, the Portuguese Government presented the 2012 State Budget proposal for Parliament’s discussion and further approval


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

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