Results 1-10 of 537
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2011: The Year in Review : France
January 27, 2012
French tax changes in 2011 affected a wide range of taxpayers. Businesses The taxation of dividends a parent company receives from a subsidiary is no longer capped at the amount of expenses the parent incurs. The thin capitalization rules now apply to the interest paid to unrelated companies when a company related to the borrowing company secures a loan, except when there is a mandatory change of control. The deductible amount of tax losses that can be carried forward against financial year profits is now limited to €1 million plus 60 percent of taxable profits above €1 million. Tax losses can be carried back only to the previous financial year and only up to €1 million. The long term capital gains tax on participating interest has increased, because the corporate income tax now applies to 10 percent of the capital gain.
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"Government Publishes 2012 Finance Acts, Amended 2011 Act"
January 27, 2012
Following their adoption by the French Parliament, the Fourth Amended Finance Act for 2011 and the Finance Act for 2012 were published in France’s official journal on December 29. The Social Security Finance Act for 2012 was published on December 22. This article focuses on the notable tax aspects of these three bills.
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Projected Reform of German Insolvency Law Recapitalization Instead of Liquidation of Companies
December 16, 2011
A large number of U.S. companies have investments in German entities, whether they be in the form of wholly owned subsidiaries, joint ventures etc. Should one of these German companies face a severe financial crisis, the U.S. shareholder must deal with German insolvency laws and procedures concerning its German subsidiary.
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Careful Planning Can Minimize Tax Consequences of Imaging Center Sales
December 13, 2011
Over the past several years, we have worked with an increasing number of clients who have been considering whether to restructure or sell their interest in their free-standing imaging centers. Partly driven by decreased reimbursement for free-standing imaging service and partly driven by hospital interest in acquiring centers, we have recently worked with groups who have sold their ownership interests in imaging centers to the hospital where they practice.
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Seeking Meaning in Meaningful Use
December 09, 2011
Reed Smith attorneys Thomas Greeson and Vicky Gormanly co-authored this article which discusses Medicare and Medicaid Electronic Health Record Incentive Programs.
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ECJ Advocate General Issues Opinion in French VAT Case
December 06, 2011
On November 17 European Court of Justice Advocate General Juliane Kokott delivered her opinion in Société Veleclair v. Ministre du budget (C-414/10), holding that article 17, section 2(b) of the Sixth VAT Directive does not allow a member state to make the right to deduct import VAT contingent on its actual payment by the taxpayer, even if the person liable for the tax and the owner of the right to deduction are the same person. She said a member state is, however, authorized to maintain such a rule on a temporary basis. Further, the taxpayer is not entitled to deduct import VAT that has not yet been paid when there is no civil obligation to pay the VAT, she said.
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Sample “Meaningful Use” Provision for use by RBMA Members in a Hospital/ Radiology Group Professional Services Agreement
November 01, 2011
Sample “Meaningful Use” Provision for use by RBMA Members in a Hospital/ Radiology Group Professional Services Agreement
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FDIC Treatment of Creditor Claims Under Orderly Liquidation Process
October 26, 2011
When a traditional nonbanking company files a case under the Bankruptcy Code, a judge is appointed to be the neutral arbiter of disputes that arise between the debtor and its creditors. Under the new insolvency regime created by Title II of the Dodd-Frank Wall Street and Consumer Protection Act (the ‘‘Act''), the Federal Deposit Insurance Corporation (the ‘‘FDIC''), who, until now, was only the receiver for banks, also may be appointed as receiver of the nonbank financial company if the Secretary of Treasury, in consultation with the President, determines that the company is in default or in danger of default, and the failure of the company would have serious adverse effects on the nation's financial stability.
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European Commission Challenges French VAT Exemption
October 24, 2011
The European Commission on September 29 referred France to the European Court of Justice over the French VAT treatment of commercial vessels operating in territorial waters. (For the referral, see Doc 2011-20676 or 2011 WTD 190-18.)
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Supplementary Budget Bill Focuses On Deficit Reduction
September 27, 2011
The French Parliament on September 8 passed the Second Supplementary Budget Bill for 2011, which focuses on new tax measures to reduce deficits. Additional tax measures have been proposed in the draft budget law for 2012, which will be presented to the Cabinet on September 28.