Searching Content indexed under Tax Authorities by Jones Day ordered by Published Date Descending.
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French Tax Update: Draft Finance Bill For 2016, New France/Germany Double Tax Treaty, And ECJ Steria Decision
This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December, (ii) the amendment signed in March 2015 in respect of the France/Germany double tax treaty, and (iii) the decision issued in early September by the European Court of Justice in the Steria case.
9 Oct 2015
Major Changes To The Delaware Unclaimed Property Audit And Voluntary Disclosure Regime That Delaware-Formed Entities Should Consider
Delaware Senate Bill 141, signed by Governor Mardell on July 22, 2015, makes significant changes to Delaware's procedures relating to unclaimed property audits and voluntary disclosures.
United States
3 Sep 2015
Abnormal Act Of Management
The decision is a good indication that, other than under exceptional circumstances, the FTA is not supposed to meddle in the daily business decisions of taxpayers.
20 Aug 2015
Retroactivity Of The Limitation On The Deductibility Of Capital Losses - August 2015
Article 18 of the Finance Law for 2012 introduced a limitation on the deductibility of capital losses incurred on the sale of shares occurring less than two years after their issuance...
19 Aug 2015
French Tax Update: Priority Preliminary Rulings - August 2015
As discussed in a previous French Tax Update, the Conseil d'Etat had referred to Conseil Constitutionnel three interesting priority preliminary rulings on the issue of constitutionality in the field of taxation.
19 Aug 2015
French Tax Update - Recently Published Noteworthy Decisions - July 2015
The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months.
7 Jul 2015
Retroactivity Of The Limitation On The Deductibility Of Capital Losses
In a nutshell, where the market value of such shares at the time of their issuance is lower than their book value, the difference may not be deducted from the taxable profits of the taxpayer at the time of the sale.
4 Jun 2015
French Tax Update - Proposed Changes To The EU Parent–Subsidiary Directive, Q2 Noteworthy Publications, And FATCA And BEPS Updates
This update will look over changes to the EU Parent–Subsidiary Directive, recent advisory opinions issued by the Committee, recent case law, and other issues.
4 Jun 2014
German Tax Court Rules On Termination Of Fiscal Unity Under International Reorganization
An intra-group reorganization involving the transfer of shares in a German subsidiary does not constitute a good cause to terminate the fiscal unity.
12 May 2014
German Constitutional Court Issues Ruling On Retroactivity Of Tax Laws
The German Constitutional Court (Bundesverfassungsgericht) issued a decision in respect to a tax law that had retroactive effect when it was enacted.
12 May 2014
German Domestic Anti-Abuse Rules Regarding The Taxation Of Partnerships Possibly Unconstitutional
The German Tax Court has requested that the Constitutional Court declare as unconstitutional domestic anti-abuse rules regarding the taxation of partnerships.
12 May 2014
German Tax Authorities Allow Tax Deductibility Of Additional Tier 1 Capital
Until recently, the German tax characterization of so-called Additional Tier 1 Capital instruments issued under the so-called Basel III framework was uncertain.
12 May 2014
Focus On The Anti-Avoidance Provision Targeting Hybrid Debt Instruments
The 2014 Finance Law has implemented another limitation of the tax deductibility of interest payments made by a French borrower to an affiliated entity.
12 May 2014
French Tax Update - Anti-Hybrid Regime Draft Guidelines and Early 2014 Noteworthy Case Law
"French Tax Update" is a periodic publication that examines the French hot topics in the field of tax.
6 May 2014
French Tax Update - A Comparison Between The French Abuse Of Law And The UK General Anti-Abuse Rule
While the abuse of law has been in place for many years under French tax law, the General Anti-Abuse Rule has only been introduced into UK tax law very recently.
2 Apr 2014
French Tax Update – March 2014
The French corporate tax rules are on a strict territoriality basis, i.e., only profits generated in France are liable to tax.
12 Mar 2014
French Tax Update
In this second French Tax Update of the year, we will first focus on one of the key provisions of the Finance Law for 2014 (Loi de finances pour 2014, 2014 Finance Law) which essentially aims at combating hybrid debt instruments put in place between French borrowers and affiliated foreign lenders.
16 Feb 2014
IRS Extends FBAR Filing Deadline For U.S. Investors In Offshore Investment Funds
As we reported recently, earlier this year representatives of the U.S. Internal Revenue Service ("IRS") indicated informally that U.S. investors in foreign private equity and hedge funds are required to report annually their fund interests on Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (an "FBAR").
United States
2 Sep 2009
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