Tax & Legal

Kategorien: Alle (2 gefunden)

1. 01. September 2025

   Loss utilization after termination of a two-tier limited par ...

   In a recently published judgment, the Supreme Tax Court decided in a case involving the transfer of a limited partnership to the sole remaining limited partner in the legal form of a limited liability company (GmbH) by way of universal succession through accrual, among other things, that the limited partner's allowable loss determined at the time of termination within the meaning of Section 15a (4) of the Income Tax Act can be offset by the limited limited company against its future profits.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: limited partnership, loss carryforward t ...
2. 22. Mai 2012

   Loss carry forward transfer only if loss maker still owned a ...

   The Supreme Tax Court has held that unused loss relief may only pass to transferee under the Reconstructions Tax Act up to December 12, 2006 if the loss making business was still held by the transferor on date of transfer.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Loss relief, loss carryforward transfer, ...