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Documents on taxation
 

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HTMLDeduction of Final Tax Losses
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
May 15, 2015, previously published on May 2015
On April 15, 2015, the Conseil d'Etat ruled on the French treatment of the tax losses incurred by a non-French subsidiary of a French parent.

 

HTMLInternal Revenue Service Issues Final Regulations under Internal Revenue Code Section 162(m)
Manes M. Merrit, Barry L. Salkin, Karen W. Scheffler; Olshan Frome Wolosky LLP;
Legal Alert/Article
May 15, 2015, previously published on May 2015
On March 31, 2015, the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”) under Internal Revenue Code (“Code”) Section 162(m) which clarify two important operational items regarding the deductibility of certain executive...

 

HTMLElection Results: A Completely New Political Map
Sophie Dworetzsky, Christopher Groves; Withers Bergman LLP;
Legal Alert/Article
May 15, 2015, previously published on May 8, 2015
Many had understandably termed this the most important election in decades, but even then no one predicted what has actually just happened - the complete recasting of the British political landscape. It can only be assumed that a number of parties will be rethinking their approach, federalism might...

 

HTMLFrench 3 Percent Tax on Distributed Income - Noncompliant with EU Law?
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
May 15, 2015, previously published on May 2015
For distributions paid out from 2012 onward, France has introduced a 3 percent tax due, with certain exceptions, by corporate taxpayers (including under certain conditions French branches of foreign companies) that distribute dividends. Given that the French corporate tax is based on a territorial...

 

HTMLTax Exempt Temporary Expatriation Allowances
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
May 15, 2015, previously published on May 2015
Pursuant to article 81 A of the French tax code, a favorable tax regime applies to temporary expatriation allowances paid out to French employees sent abroad for business trips exceeding 24 hours. This regime is inter alia subject to the condition that these allowances do not exceed 40 percent of...

 

HTMLAction to Quiet Title for Property Purchased at Tax Foreclosure Auction
Scott M. Brookens; Smith Haughey Rice & Roegge, P.C.;
Legal Alert/Article
May 15, 2015
In Michigan, if property taxes and assessments go unpaid, officials in the county in which the property is located have authority to place a tax lien on the offending property. In the event interested parties fail to extinguish the tax lien in a timely manner, the county may recover all unpaid...

 

HTMLIllustration of the VAT Recovery Principles Applicable to Sales of Shares
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
May 15, 2015, previously published on May 2015
The Conseil d'Etat has already had the opportunity to rule on the recoverability of the input VAT attached to the costs pertaining to an acquisition of shares.

 

HTMLVAT Treatment of Acquisition Costs Recharged to Other Entities of a Group
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
May 15, 2015, previously published on May 2015
On January 23, 2015, the Conseil d''Etat issued a decision on whether the turnover attributable to the recharge to other entities of a group of acquisition costs generated within the course of a corporate reorganization could be taken into account for the purposes of the determination of a holding...

 

HTMLCarried-Forward Tax Losses May Be Offset Against Tax Profits Only After All Expenses have been Deducted
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
May 15, 2015, previously published on May 2015
Pursuant to the French tax code, corporation income tax is applied on the net accounting profits, as adjusted for French tax purposes. Tax losses available for carry-forward are deemed to constitute an expense for corporation income tax purposes, even though they do not constitute an expense from...

 

HTMLApplication of VAT Rules to Transactions between Head Office and Permanent Establishment
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
May 15, 2015, previously published on May 2015
For French corporation tax purposes, a French permanent establishment (PE) of a non-French tax resident corporation is treated as a separate taxable person including, generally, in its dealings with its head office. International tax treaties, signed by France, define how income and expenses...

 


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