Advance tax ruling


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Advance tax ruling

A written statement sought by a taxpayer from the tax authorities about the tax implications of a transaction. It is often a precondition for closing the transaction because an adverse tax ruling may make the transaction (e.g. a merger) financially unviable.
References in periodicals archive ?
Conversion of preference shares into ordinary shares through mandatory conversion pursuant to the terms of the articles of association is not regarded as a taxable sale according to an advance tax ruling decided by the Swedish Council for Advance Tax Rulings on November 7, 2008, which was upheld by the Swedish Supreme Administrative Court in a judgment on May 14, 2009.
-Swedbank sets date for preference share conversion
Starting with 1991 this board has been transformed into a semi-judiciary independent body named the Council of Advance Tax Ruling. To the Swedish AIFS procedure both the tax payers and the National Fiscal Committee may apply.
The Anticipated Individualized Fiscal Solution
The changes include the introduction of a formal advance tax ruling procedure and a step up opportunity on certain conversions of a corporation into a partnership but eliminating at the same time a loophole in the international participation exemption.
Overview On M&A and Takeovers
Advance tax ruling is a procedure that allows taxpayers to achieve certainty concerning the tax consequences of a contemplated transaction.
Resolving legal uncertainty: the unfulfilled promise of advance tax rulings
The designation is obtained by requesting an advance tax ruling. The difficulty in making the request or obtaining the ruling is that the term "project" is not defined in the Act and there is no guidance available in opinions, public rulings, published guidelines, and, arguably, the jurisprudence to aid taxpayers and CRA in making the determination.
Pending income tax issues: December 7, 2004
Finnish-Swedish IT company TietoEnator Corporation said on Tuesday (6 July) that it had received an advance tax ruling regarding the parent company asset write-downs booked and announced on 21 April 2004.
TietoEnator Corporation books deferred tax asset of EUR119m
The request was for an advance tax ruling on their plans to move over $2 billion of assets to the US.
Behind closed doors ... (and the Feds want to keep it that way)
On March 8, 1991, a law firm acting for a family trust asked Revenue Canada for an advance tax ruling to verify that public company shares held within the trust could leave Canada on a tax-free basis.
Loop hole
It said common features of deals arranged by PwC that it investigated saw the companies all set up subsidiaries in Luxembourg where they were protected by advance tax rulings from the authorities.
PWC disagree with tax avoidance conclusions; TAX
The decision came after the Canadian government stopped providing advance tax rulings on income trust offerings pending a tax review.
Jazz Air IPO on hold
A study conducted by the EU's accountancy lobby group, the Federation des Experts Comptables (FEE), has concluded that advance tax rulings in the EU often involve different treatment in the various different countries surveyed.
HARMFUL TAX PRACTICES: ACCOUNTANTS POINT TO UNEVEN RULINGS ACROSS THE EU
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