20. August 2020 Federal Ministry of Finance: draft circular on the applicati ... The Federal Ministry of Finance has sent the draft of a Ministry circular on the application of Section 8d of the Corporation Tax Act (CTA) – continuance-bound loss carry-forward after loss forfeiture - to the professional associations for comment. Kategorien: Official PronouncementsSchlagwörter: loss carry forward, continuance-bound ta ...
05. April 2016 Forfeiture of loss relief on upstream merger The Supreme Tax Court has held that an upstream merger leads to new assets in the accounts of the parent (surviving entity) and thus to forfeiture of that company’s remaining loss carry-forward if the new assets are substantial. Kategorien: Supreme Tax Court casesSchlagwörter: loss carry forward, Upstream merger, Los ...
20. Januar 2011 Upstream merger does not imperil loss carry forward of survi ... The Supreme Tax Court has held that a downstream, but not an upstream, merger leads to new assets for the surviving entity that can imperil its loss carry forward. Kategorien: Supreme Tax Court casesSchlagwörter: loss carry forward, share acquisition, s ...
