Suchergebnisse für: `effectively-connected` (3 gefunden)

1. 11. Juni 2015

   5% non-deductible deemed expense for foreign dividends can i ...

   An ECJ advocate general has suggested the court hold that the 5% effectively connected expense add-back for foreign dividends infringes a company’s freedom of establishment if an otherwise comparable domestic company could avoid the add-back by joining a tax group.

   Kategorien: From Europe

   Schlagwörter: foreign dividend, tax group, directly co ...
2. 15. November 2012

   5% dividend expense disallowance restricts freedom of establ ...

   The Supreme Tax Court has held that the 5% expense disallowance on tax-free dividends was, up to 2002, a restriction on the freedom of establishment rather than of capital movement and could thus be upheld in respect of a 33% share in a US company.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: freedom of establishment, expense disall ...
3. 02. März 2011

   No bad debt deduction on tax-free sale of shares

   The Supreme Tax Court has held that irrecoverable proceeds from the tax-free sale of shares reduce the tax-free gain and are not a deductible bad debt.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: capital gain, bad debt