Suchergebnisse für: `loss` (286 gefunden)

1. 11. Juni 2015

   Non-deductible loss on investment can include exchange loss

   The ECJ has held that if a country excludes capital gains and losses on investments from taxation, the exclusion may also extend to that part of the loss that directly resulted from exchange rate fluctuations.

   Kategorien: From Europe

   Schlagwörter: capital gain, loss on investment, exchan ...
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, ...
3. 20. Januar 2011

   No relief for loss of foreign subsidiary until final

   The Supreme Tax Court has held that even if a company is entitled to offset the loss of its foreign subsidiary at all, it cannot do so before the loss becomes irrecoverable.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Loss relief, write-down, irrecoverable, ...
4. 11. Juni 2024

   No application of loss forfeiture rules for losses allocated ...

   The loss forfeiture rules of Section 8c of the Corporation Tax Act in the version valid for 2014 are not applicable to deductible losses which are allocated to a corporation as partner of a limited partnership pursuant to Section 15a Income Tax Act. With this decision, the Supreme Tax Court contradicts the view of the tax administration.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: partnership income, Loss relief
5. 03. September 2014

   Loss offset deferral unconstitutional?

   The Supreme Tax Court has referred to the Constitutional Court on whether a confiscatory effect of the loss offset deferral provisions can be a breach of the equal treatment requirement of the constitution.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: minimum taxation, loss offset
6. 25. Mai 2011

   1999 minimum taxation rules do not affect loss carry-back to ...

   The Supreme Tax Court has held that the 1999 introduction of “minimum taxation” rules limiting loss offset by income type do not apply to a 1999 loss carried back to 1998.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: minimum taxation, loss offset, loss carr ...
7. 27. März 2014

   No refusal of relief under tax deferral scheme rules for unp ...

   The Supreme Tax Court has held that a loss incurred on an investment project of a closed-circle investment fund can be deducted by investors from their other income if the loss was not pre-planned and factored into the fund’s yield calculations.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: investment funds, tax deferral scheme
8. 27. März 2013

   No resurrection of statue-barred loss on tax amnesty

   The Supreme Tax Court has held that a tax evader who came forward under an amnesty could not offset a previously unreported capital loss against his income declared in retrospect, as tax had not been evaded on the loss, now statute-barred under normal rules.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: tax amnesty, statute-bar, limitation
9. 25. April 2014

   Final PE loss abroad offset at home

   The Supreme Tax Court has held that a foreign PE loss that for all practical purposes cannot be offset in its country of origin can be offset in German as the country of the head office.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: permanent establishment (PE), loss abroa ...
10. 13. Januar 2017

    Amendment of tax loss utilisation rules for corporations

    Under certain conditions, changes in shareholders and the admission of new investors will in future be possible without giving rise to a forfeiture of losses carried-forward. On 23 December 2016 the Act for the Further Development of Tax Loss Utilisation for Corporations was published after having been adopted by the German Parliament (Bundestag and Bundesrat) on 20 December 2016.

    Kategorien: PwC Reports, Legislation

    Schlagwörter: Corporation tax, curtailment of losses, ...
11. 04. Februar 2016

    Loss forfeiture exemption for troubled businesses rejected

    The ECJ has upheld a Commission ruling to the effect that the exemption from the provision for loss forfeiture on change of shareholders for troubled companies being rescued constitutes unlawful state aid.

    Kategorien: From Europe

    Schlagwörter: loss forfeiture, change of shareholders, ...
12. 02. Februar 2011

    Commission objects to enhanced loss relief for troubled comp ...

    The European Commission has concluded that the rule exempting troubled companies from the loss relief forfeiture on change of shareholders is unauthorized state aid.

    Kategorien: From Europe

    Schlagwörter: Steuern / Tax
13. 23. Oktober 2014

    Merger loss of life assurance company partially deductible

    The Supreme Tax Court has held that the merger loss of a life assurance company is deductible insofar as it arose from an excessive book value of the shares in the acquired company.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: merger loss, like assurance
14. 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 cases

    Schlagwörter: loss carry forward, Upstream merger, Los ...
15. 25. Oktober 2021

    Loss utilisation restriction (Section 2a (1) Sentence 1 No. ...

    According to a decision of the Supreme Tax Court published on 21 October 2021, the loss of a silent partner's contribution, which is reflected as a partial write-down for tax purposes, does not fall within the scope of the loss utilisation restriction under Section 2a (1) Sentence 1 No. 5 in conjunction with Sentence 2 Income Tax Act (ITA).

    Kategorien: Tax Court

    Schlagwörter: investment write-down, silent partnershi ...
16. 09. August 2021

    Loss on exchange of profit participation rights can be offse ...

    The Regional Tax Court of Muenster held that a loss from the exchange of profit participation rights for shares in a registered cooperative ("eG") and bonds may be set off against income from capital investments. Thus, the tax office's attempt to regard the loss as belonging to the non-taxable private asset portfolio of the plaintiff failed.

    Kategorien: Tax Court

    Schlagwörter: loss offset, exchange gain or loss, prof ...
17. 26. Januar 2011

    No serious doubt on long enforcebility of loss subvention cl ...

    The Supreme Tax Court has held that there is no serious doubt that a profit pooling agreement must provide for a ten year statute bar on loss subvention claims of an Organschaft subsidiary.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: Organschaft, profit pooling agreement, L ...
18. 25. Mai 2011

    Loss offset limitation 1999-2003 only applies to notional lo ...

    The Supreme Tax Court has held that the 1999-2003 “minimum taxation” rules apply to “paper” losses, but not to those borne with true economic effect.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: minimum taxation, loss offset
19. 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 cases

    Schlagwörter: loss carry forward, share acquisition, s ...
20. 14. Dezember 2011

    Vehicle lessor to provide for planned loss on sale

    The Supreme Tax Court has held that a truck lessor may accumulate a provision to cover an agreed loss on sale after the lease period in proportion to the rental income.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: leased trucks, contract residual value, ...
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