Conducting Business in Ukraine 2016 Conducting Business in Ukraine 2016 Conducting Business in Ukraine 2016 Baker & McKenzie Renaissance Business Center 24 Bulvarno-Kudriavska (Vorovskoho) St.
Doing Business in the Slovak Republic 2016 Doing Business in the Slovak Republic 2016 Preface Since gaining its independence in 1993, the Slovak Republic has been adopting new laws at a rapid pace. As a country in transition, its legal system continues to develop. Therefore, the Prague office of Baker & McKenzie and its Slovak counsel Marek & Partners have prepared the document Doing Business in the Slovak Republic as a general guide for any company or individual considering an investment in the Slovak Republic.
High Court says "Yes"
Need to know
In a win for creditors of insolvent companies, on 10 December 2015 the High Court determined that the obligation of a liquidator under section 254(1)(d) of the Income Tax Assessment Act 1936 (Cth) (1936 Act) to retain sufficient funds to pay tax on assets realised during the winding up only arises after a tax assessment has been made. If the funds are distributed prior to a tax assessment being made, then the obligation does not arise.
Baker & McKenzie Alert Client Alert 28 SEPTEMBER 2015 Download Forward Contact Us Visit Our Website Providing the Commissioner of Taxation with access to records - even liquidators cannot escape Need to know The Federal Court has recently determined that when the Commissioner of Taxation is a creditor of a company in liquidation, he or she is not required to obtain a court order under section 486 of the Corporations Act 2001 (Cth) (Corporations Act), unlike all other creditors, before requiring the Liquidator to make available the company's records for inspection.
The Tax Cuts and Jobs Act signed into law on December 22, 2017, amended the Internal Revenue Code of 1986 (IRC) and made significant changes to the treatment of individual and corporate taxpayers beginning January 1, 2018. While many understand that the overall corporate tax rate is going down, the specific effects of this tax reform on distressed companies, debtors, creditors, and lenders are still being uncovered. Practical Law asked Patrick M. Cox of Baker McKenzie LLP to discuss his views on the Tax Cuts and Jobs Act (TCJA) and its potential impact on the Chapter 11 process.
This is part of a series of articles discussing restructuring and insolvency related provisions of the Tax Cuts and Jobs Act, which is now expected to become law this week (the “Act”).
Previously we discussed net operating losses (“NOLs”) and cancellation of the debt (“COD”). The provisions on NOLs have generally remained the same (adopting the Senate version of the revisions, but immediately capping the use of NOLs to 80% of taxable income). However, the changes to COD rules we discussed are not part of the current version of the Act.
This is the second part in a series of articles discussing certain restructuring and insolvency related provisions of the Tax Reform. Previously we discussed net operating losses (“NOLs”), and noted that the House and Senate plans are quite similar when it comes to NOLs. That is not the case with the provisions in H.R. 1 that relate to cancellation of the debt (“COD”).
Congress is attempting to pass tax reform legislation and presently the House of Representatives and the Senate have separate proposals under consideration (separately, H.R. 1 and the Senate Plan, respectively, and collectively, “Tax Reform”). The Tax Reform is changing daily, but one thing seems likely and that is that the Tax Reform will change the treatment of net operating losses (“NOLs”). These changes would have the most significant impact to bankruptcy cases filed after December 31, 2017.
On September 19, the Dutch District Court ruled in the first ever Dutch court case on the transfer pricing implications of a large business restructuring and confirmed the legal certainty that taxpayers can derive from thorough transfer pricing documentation. The case was litigated by the Tax Dispute Resolution group of Baker McKenzie Amsterdam.
DBI 2017 - A5 With Bleed.indd 3 20.02.2017 8:22:56 Doing Business in Russia 2017 Baker & McKenzie - CIS, Limited Moscow Office White Gardens, 10th Floor 9 Lesnaya Street Moscow 125047, Russia Telephone: +7 495 787 27 00 Fax: +7 495 787 27 01 [email protected] St. Petersburg Office BolloevCenter, 2nd Floor 4A Grivtsova Lane St.