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HTMLDraft Guidance for the General Anti-Avoidance Rule
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On July 3, 2014, the State Administration of Taxation (the "SAT") released a discussion draft on the Administrative Measures on the General Anti-Avoidance Rule (the "Draft Measures). The General Anti-Avoidance Rule ("GAAR") was introduced in China Corporate Income Tax Law...

 

HTMLTax Evasion: Risk of Discovery Increases - Amended Tax Return as a Way Out
Michael Rainer, Michael Rainer; GRP Rainer LLP;
Legal Alert/Article
October 16, 2014, previously published on October 14, 2014
It is becoming increasingly difficult for tax evaders to remain undetected due to the automatic exchange of information between EU member states, particularly as Switzerland has signalled its willingness to cooperate.

 

HTMLSDLT and Property Investment Funds
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
The UK government has announced that it will be looking at whether any changes are needed to current stamp duty land tax ("SDLT") rules to cater for two specific forms of collective investment scheme designed for investors in the UK market.

 

HTMLDutch Innovation Box Regime for Intangibles is Clarified in Decree
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
The Innovation Box was introduced in 2007 to encourage companies to innovate and increase their research and development ("R&D"). Under this optional regime, subject to certain conditions, Dutch corporate taxpayers are taxed at an effective rate of 5 percent. In the newly published...

 

HTMLLuxembourg-France Tax Treaty: Amendment Signed on September 5, 2014
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On September 5, 2014, French Minister of Finance Michel Sapin and Luxembourgian Minister of Finance Pierre Gramegna signed an amendment to the France-Luxembourg Tax Treaty (1958) (the "Tax Treaty"), as amended by the 1970 exchange of letters and by the 1970, 2006, and 2009 protocols.

 

HTMLThe Netherlands to Expand its Fiscal Unity Regime to Second-Tier Subsidiaries and Sister Companies Following EU Court of Justice Ruling
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On June 12, 2014, the EU Court of Justice ("ECJ") ruled in two joint cases that the Dutch fiscal unity regime infringes on the EU freedom of establishment, because it does not allow a fiscal unity between (i) a Dutch resident parent company and its second-tier Dutch resident subsidiary...

 

HTML"Protectionist" French Excise Tax on Certain Types of Beer Complies with EU Law
Jones Day;
Legal Alert/Article
October 16, 2014, previously published on October 2014
On September 13, 2014, it was reported by the trade press that the European Commission had found that the increase by 160 percent of French excise tax on certain types of high-alcohol-content and luxury beers that was introduced on January 1, 2013 did not fall afoul of the free-market principles of...

 

HTML3 Years Or 18 Months - How Long Is The Redemptive Period?
Wesley M. Plaisance; Breazeale, Sachse & Wilson, L.L.P.;
Legal Alert/Article
October 15, 2014, previously published on October 9, 2014
Most tax sale purchasers and title attorneys know that tax sale title is subject to redemption within a three (3) year peremptive period from the date of recordation. However, the Louisiana Constitution does contain one exception to this rule. In the City of New Orleans, property that is...

 

HTMLState of Rio de Janeiro Decree No. 44,974/2014: Extension of Deadline for Adherence to Tax Debt Payment Program (Tax Amnesty Program)
Marina Cyrino, Ivan Tauil; Tauil & Chequer Advogados in association with Mayer Brown LLP;
Legal Alert/Article
October 14, 2014, previously published on October 6, 2014
Decree No. 44,974/2014 was published in the Official Gazette on September 30, 2014. The Decree extends until November 30,2014,the deadline to enroll in the Tax Debt Payment Program for the State of Rio de Janeiro, which was established in Decree No. 44,780/2014 and ICMS Convention No. 128/2013.

 

Adobe PDFLike a Hot Knife Through Butter: The US Congress and Internal Revenue Service Pierce Straight Through Barrier Options
Mark H. Leeds; Mayer Brown LLP;
Legal Alert/Article
October 14, 2014, previously published on October 7, 2014
The Internal Revenue Service (IRS) has disputed the tax consequences for holders of barrier call options for at least five years. Recently, however, Congress and the IRS have sought to use the court of public opinion and the rules for accounting method changes to influence the outcome in tax audits...

 


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