Sentences with phrase «controlled foreign companies»

The litigation concerns claims alleging that certain provisions of the corporation tax legislation concerning the provisions regarding controlled foreign companies and / or the provisions which make dividends received by UK corporations from companies resident outside the UK subject to corporation tax are contrary to the EC Treaty or the allocation of taxing provisions in Double Taxation Conventions.

An outdated, not fit for purpose Controlled Foreign Companies (CFC) regime, coupled with the «Check the Box» election, no exemption for foreign dividends, and pliant treaty partners like Luxembourg and Ireland (who can't compete unless they drop their Corporation Tax aspirations), and you have the perfect (tax) storm: very low effective corporate tax rate and long term tax deferral (there being no incentive for the likes of Apple to repatriate their profits to the US).

A full consultation document with detailed proposals on all the areas of foreign profits taxation under review is very unlikely - but updated proposals on changes to the controlled foreign companies regime and a new restriction on interest expense are likely before the end of the year and could be unveiled in the pre-budget report.

This may raise the issue of Treasury Consent and the controlled foreign company (CFC) rules.

Guernsey does not have specific anti-avoidance rules such as transfer pricing, thin capitalisation or controlled foreign company rules.

AstraZeneca v HMRC David Bedenham was instructed by HMRC in this long running dispute relating to transfer pricing and controlled foreign company issues.

AstraZeneca v HMRC Long running dispute relating to transfer pricing and controlled foreign company issues.

Not exact matches

Important factors that could cause actual results to differ materially from those reflected in such forward - looking statements and that should be considered in evaluating our outlook include, but are not limited to, the following: 1) our ability to continue to grow our business and execute our growth strategy, including the timing, execution, and profitability of new and maturing programs; 2) our ability to perform our obligations under our new and maturing commercial, business aircraft, and military development programs, and the related recurring production; 3) our ability to accurately estimate and manage performance, cost, and revenue under our contracts, including our ability to achieve certain cost reductions with respect to the B787 program; 4) margin pressures and the potential for additional forward losses on new and maturing programs; 5) our ability to accommodate, and the cost of accommodating, announced increases in the build rates of certain aircraft; 6) the effect on aircraft demand and build rates of changing customer preferences for business aircraft, including the effect of global economic conditions on the business aircraft market and expanding conflicts or political unrest in the Middle East or Asia; 7) customer cancellations or deferrals as a result of global economic uncertainty or otherwise; 8) the effect of economic conditions in the industries and markets in which we operate in the U.S. and globally and any changes therein, including fluctuations in foreign currency exchange rates; 9) the success and timely execution of key milestones such as the receipt of necessary regulatory approvals, including our ability to obtain in a timely fashion any required regulatory or other third party approvals for the consummation of our announced acquisition of Asco, and customer adherence to their announced schedules; 10) our ability to successfully negotiate, or re-negotiate, future pricing under our supply agreements with Boeing and our other customers; 11) our ability to enter into profitable supply arrangements with additional customers; 12) the ability of all parties to satisfy their performance requirements under existing supply contracts with our two major customers, Boeing and Airbus, and other customers, and the risk of nonpayment by such customers; 13) any adverse impact on Boeing's and Airbus» production of aircraft resulting from cancellations, deferrals, or reduced orders by their customers or from labor disputes, domestic or international hostilities, or acts of terrorism; 14) any adverse impact on the demand for air travel or our operations from the outbreak of diseases or epidemic or pandemic outbreaks; 15) our ability to avoid or recover from cyber-based or other security attacks, information technology failures, or other disruptions; 16) returns on pension plan assets and the impact of future discount rate changes on pension obligations; 17) our ability to borrow additional funds or refinance debt, including our ability to obtain the debt to finance the purchase price for our announced acquisition of Asco on favorable terms or at all; 18) competition from commercial aerospace original equipment manufacturers and other aerostructures suppliers; 19) the effect of governmental laws, such as U.S. export control laws and U.S. and foreign anti-bribery laws such as the Foreign Corrupt Practices Act and the United Kingdom Bribery Act, and environmental laws and agency regulations, both in the U.S. and abroad; 20) the effect of changes in tax law, such as the effect of The Tax Cuts and Jobs Act (the «TCJA») that was enacted on December 22, 2017, and changes to the interpretations of or guidance related thereto, and the Company's ability to accurately calculate and estimate the effect of such changes; 21) any reduction in our credit ratings; 22) our dependence on our suppliers, as well as the cost and availability of raw materials and purchased components; 23) our ability to recruit and retain a critical mass of highly - skilled employees and our relationships with the unions representing many of our employees; 24) spending by the U.S. and other governments on defense; 25) the possibility that our cash flows and our credit facility may not be adequate for our additional capital needs or for payment of interest on, and principal of, our indebtedness; 26) our exposure under our revolving credit facility to higher interest payments should interest rates increase substantially; 27) the effectiveness of any interest rate hedging programs; 28) the effectiveness of our internal control over financial reporting; 29) the outcome or impact of ongoing or future litigation, claims, and regulatory actions; 30) exposure to potential product liability and warranty claims; 31) our ability to effectively assess, manage and integrate acquisitions that we pursue, including our ability to successfully integrate the Asco business and generate synergies and other cost savings; 32) our ability to consummate our announced acquisition of Asco in a timely matter while avoiding any unexpected costs, charges, expenses, adverse changes to business relationships and other business disruptions for ourselves and Asco as a result of the acquisition; 33) our ability to continue selling certain receivables through our supplier financing program; 34) the risks of doing business internationally, including fluctuations in foreign current exchange rates, impositions of tariffs or embargoes, compliance with foreign laws, and domestic and foreign government policies; and 35) our ability to complete the proposed accelerated stock repurchase plan, among other foreign currency exchange rates; 9) the success and timely execution of key milestones such as the receipt of necessary regulatory approvals, including our ability to obtain in a timely fashion any required regulatory or other third party approvals for the consummation of our announced acquisition of Asco, and customer adherence to their announced schedules; 10) our ability to successfully negotiate, or re-negotiate, future pricing under our supply agreements with Boeing and our other customers; 11) our ability to enter into profitable supply arrangements with additional customers; 12) the ability of all parties to satisfy their performance requirements under existing supply contracts with our two major customers, Boeing and Airbus, and other customers, and the risk of nonpayment by such customers; 13) any adverse impact on Boeing's and Airbus» production of aircraft resulting from cancellations, deferrals, or reduced orders by their customers or from labor disputes, domestic or international hostilities, or acts of terrorism; 14) any adverse impact on the demand for air travel or our operations from the outbreak of diseases or epidemic or pandemic outbreaks; 15) our ability to avoid or recover from cyber-based or other security attacks, information technology failures, or other disruptions; 16) returns on pension plan assets and the impact of future discount rate changes on pension obligations; 17) our ability to borrow additional funds or refinance debt, including our ability to obtain the debt to finance the purchase price for our announced acquisition of Asco on favorable terms or at all; 18) competition from commercial aerospace original equipment manufacturers and other aerostructures suppliers; 19) the effect of governmental laws, such as U.S. export control laws and U.S. and foreign anti-bribery laws such as the Foreign Corrupt Practices Act and the United Kingdom Bribery Act, and environmental laws and agency regulations, both in the U.S. and abroad; 20) the effect of changes in tax law, such as the effect of The Tax Cuts and Jobs Act (the «TCJA») that was enacted on December 22, 2017, and changes to the interpretations of or guidance related thereto, and the Company's ability to accurately calculate and estimate the effect of such changes; 21) any reduction in our credit ratings; 22) our dependence on our suppliers, as well as the cost and availability of raw materials and purchased components; 23) our ability to recruit and retain a critical mass of highly - skilled employees and our relationships with the unions representing many of our employees; 24) spending by the U.S. and other governments on defense; 25) the possibility that our cash flows and our credit facility may not be adequate for our additional capital needs or for payment of interest on, and principal of, our indebtedness; 26) our exposure under our revolving credit facility to higher interest payments should interest rates increase substantially; 27) the effectiveness of any interest rate hedging programs; 28) the effectiveness of our internal control over financial reporting; 29) the outcome or impact of ongoing or future litigation, claims, and regulatory actions; 30) exposure to potential product liability and warranty claims; 31) our ability to effectively assess, manage and integrate acquisitions that we pursue, including our ability to successfully integrate the Asco business and generate synergies and other cost savings; 32) our ability to consummate our announced acquisition of Asco in a timely matter while avoiding any unexpected costs, charges, expenses, adverse changes to business relationships and other business disruptions for ourselves and Asco as a result of the acquisition; 33) our ability to continue selling certain receivables through our supplier financing program; 34) the risks of doing business internationally, including fluctuations in foreign current exchange rates, impositions of tariffs or embargoes, compliance with foreign laws, and domestic and foreign government policies; and 35) our ability to complete the proposed accelerated stock repurchase plan, among other foreign anti-bribery laws such as the Foreign Corrupt Practices Act and the United Kingdom Bribery Act, and environmental laws and agency regulations, both in the U.S. and abroad; 20) the effect of changes in tax law, such as the effect of The Tax Cuts and Jobs Act (the «TCJA») that was enacted on December 22, 2017, and changes to the interpretations of or guidance related thereto, and the Company's ability to accurately calculate and estimate the effect of such changes; 21) any reduction in our credit ratings; 22) our dependence on our suppliers, as well as the cost and availability of raw materials and purchased components; 23) our ability to recruit and retain a critical mass of highly - skilled employees and our relationships with the unions representing many of our employees; 24) spending by the U.S. and other governments on defense; 25) the possibility that our cash flows and our credit facility may not be adequate for our additional capital needs or for payment of interest on, and principal of, our indebtedness; 26) our exposure under our revolving credit facility to higher interest payments should interest rates increase substantially; 27) the effectiveness of any interest rate hedging programs; 28) the effectiveness of our internal control over financial reporting; 29) the outcome or impact of ongoing or future litigation, claims, and regulatory actions; 30) exposure to potential product liability and warranty claims; 31) our ability to effectively assess, manage and integrate acquisitions that we pursue, including our ability to successfully integrate the Asco business and generate synergies and other cost savings; 32) our ability to consummate our announced acquisition of Asco in a timely matter while avoiding any unexpected costs, charges, expenses, adverse changes to business relationships and other business disruptions for ourselves and Asco as a result of the acquisition; 33) our ability to continue selling certain receivables through our supplier financing program; 34) the risks of doing business internationally, including fluctuations in foreign current exchange rates, impositions of tariffs or embargoes, compliance with foreign laws, and domestic and foreign government policies; and 35) our ability to complete the proposed accelerated stock repurchase plan, among other Foreign Corrupt Practices Act and the United Kingdom Bribery Act, and environmental laws and agency regulations, both in the U.S. and abroad; 20) the effect of changes in tax law, such as the effect of The Tax Cuts and Jobs Act (the «TCJA») that was enacted on December 22, 2017, and changes to the interpretations of or guidance related thereto, and the Company's ability to accurately calculate and estimate the effect of such changes; 21) any reduction in our credit ratings; 22) our dependence on our suppliers, as well as the cost and availability of raw materials and purchased components; 23) our ability to recruit and retain a critical mass of highly - skilled employees and our relationships with the unions representing many of our employees; 24) spending by the U.S. and other governments on defense; 25) the possibility that our cash flows and our credit facility may not be adequate for our additional capital needs or for payment of interest on, and principal of, our indebtedness; 26) our exposure under our revolving credit facility to higher interest payments should interest rates increase substantially; 27) the effectiveness of any interest rate hedging programs; 28) the effectiveness of our internal control over financial reporting; 29) the outcome or impact of ongoing or future litigation, claims, and regulatory actions; 30) exposure to potential product liability and warranty claims; 31) our ability to effectively assess, manage and integrate acquisitions that we pursue, including our ability to successfully integrate the Asco business and generate synergies and other cost savings; 32) our ability to consummate our announced acquisition of Asco in a timely matter while avoiding any unexpected costs, charges, expenses, adverse changes to business relationships and other business disruptions for ourselves and Asco as a result of the acquisition; 33) our ability to continue selling certain receivables through our supplier financing program; 34) the risks of doing business internationally, including fluctuations in foreign current exchange rates, impositions of tariffs or embargoes, compliance with foreign laws, and domestic and foreign government policies; and 35) our ability to complete the proposed accelerated stock repurchase plan, among other foreign current exchange rates, impositions of tariffs or embargoes, compliance with foreign laws, and domestic and foreign government policies; and 35) our ability to complete the proposed accelerated stock repurchase plan, among other foreign laws, and domestic and foreign government policies; and 35) our ability to complete the proposed accelerated stock repurchase plan, among other foreign government policies; and 35) our ability to complete the proposed accelerated stock repurchase plan, among other things.

The same can't be said of Ottawa, which is trying at once to attract investment and diversify Canada's export markets without ceding control of our resources to companies controlled by powerful foreign governments (read: China).

Treasury's Office of Foreign Assets Control added six individuals and 10 companies and other entities to its sanctions list, saying they have helped people previously penalized for North Korea's weapons development, facilitated North Korea's energy sector and enabled entities to bypass sanctions to get access to the U.S. and international financial system.

The survey asked «If a company, bank or investment fund controlled by a foreign government were trying to buy a controlling stake in a major Canadian company, how would you feel if the foreign government were...?»

«The future is foreign markets, so the last thing you want to do if you are a coal company is to give up a U.S. seat in the international climate discussions and let the Europeans control the agenda,» said the official, who asked not to be named because he was not authorized to speak publicly on the issue.

Here's a familiar storyline: a foreign mining giant tries to take control of a large domestic potash company, sparking a nationalistic uproar in defence of what is deemed a strategic resource.

The arrests, by national intelligence agents, marked the first at a Western oil firm in Venezuela and represent a dramatic escalation of growing tensions between PDVSA and foreign companies over control of supply contracts.

The arrests, by national intelligence agents, marked the first at a Western oil firm in Venezuela and represent a dramatic escalation of growing tensions between PDVSA and foreign companies over control of supply contracts, the sources told Reuters.

Currently CFIUS reviews only transactions that give foreign parties majority control of a US company that develops, sells or licenses advanced technologies with potential military applications.

The counterargument, which carries much weight in Quebec, is that the province has lost too many important companies to foreign control, just to see jobs cut and capital investment disappear.

As long as foreign investors aren't provided with a clear process, and as long as they are unable to take controlling interests in Canadian firms, these muddled rules will likely continue to increase the cost of attracting capital for Canadian resource companies.

Among the factors that could cause actual results to differ materially are the following: (1) worldwide economic, political, and capital markets conditions and other factors beyond the Company's control, including natural and other disasters or climate change affecting the operations of the Company or its customers and suppliers; (2) the Company's credit ratings and its cost of capital; (3) competitive conditions and customer preferences; (4) foreign currency exchange rates and fluctuations in those rates; (5) the timing and market acceptance of new product offerings; (6) the availability and cost of purchased components, compounds, raw materials and energy (including oil and natural gas and their derivatives) due to shortages, increased demand or supply interruptions (including those caused by natural and other disasters and other events); (7) the impact of acquisitions, strategic alliances, divestitures, and other unusual events resulting from portfolio management actions and other evolving business strategies, and possible organizational restructuring; (8) generating fewer productivity improvements than estimated; (9) unanticipated problems or delays with the phased implementation of a global enterprise resource planning (ERP) system, or security breaches and other disruptions to the Company's information technology infrastructure; (10) financial market risks that may affect the Company's funding obligations under defined benefit pension and postretirement plans; and (11) legal proceedings, including significant developments that could occur in the legal and regulatory proceedings described in the Company's Annual Report on Form 10 - K for the year ended Dec. 31, 2017, and any subsequent quarterly reports on Form 10 - Q (the «Reports»).

It is in China's interest to respect private intellectual property rights if it wants to move beyond being described as the world's factory: if it wants would want to move from «made in China,» where goods are largely produced under foreign companies» control, to «made by China,» where Chinese companies own the brains behind the manufacturing and design of goods.

«The Marriot incident shows that, for foreign companies, the price of operating in China is succumbing to the Communist Party's thought control,» Hamilton said.

However, as part of its response, the USTR also lodged a WTO case last month challenging Chinese policies it said unfairly limit foreign companies» control over their technology.

This discussion also does not consider any specific facts or circumstances that may be relevant to holders subject to special rules under the U.S. federal income tax laws, including, without limitation, certain former citizens or long - term residents of the United States, partnerships or other pass - through entities, real estate investment trusts, regulated investment companies, «controlled foreign corporations,» «passive foreign investment companies,» corporations that accumulate earnings to avoid U.S. federal income tax, banks, financial institutions, investment funds, insurance companies, brokers, dealers or traders in securities, commodities or currencies, tax - exempt organizations, tax - qualified retirement plans, persons subject to the alternative minimum tax, persons that own, or have owned, actually or constructively, more than 5 % of our common stock and persons holding our common stock as part of a hedging or conversion transaction or straddle, or a constructive sale, or other risk reduction strategy.

If Beijing relaxes foreign ownership limit in its auto industry, international companies may seek greater or full control of their ventures in China — a move that would hurt their local partners, analysts at Daiwa Capital Markets said.

The main beneficiaries include U.S. - based solar manufacturers Suniva and SolarWorld - both controlled by foreign parent companies.

Reality: The Investment Canada Act applies to any acquisition of a Canadian company by a foreign - controlled company, regardless of whether the purchaser is already operating in Canada.

In the past few weeks, Iranian businessmen with links to foreign companies have been detained, interrogated and warned against wading into economic monopolies controlled by the Revolutionary Guard Corps, according to several businessmen interviewed inside and outside of Iran.

Without limiting the foregoing, under no circumstances shall the Company be held liable for any delay or failure in performance resulting directly or indirectly from acts of nature, forces, or causes beyond its reasonable control, including, without limitation, Internet failures, computer equipment failures, telecommunication equipment failures, other equipment failures, electrical power failures, strikes, labour disputes, riots, insurrections, civil disturbances, shortages of labour or materials, fires, floods, storms, explosions, acts of God, war, governmental actions, orders of domestic or foreign courts or tribunals, non-performance of 3rd - parties, or loss of or fluctuations in heat, light, or air conditioning.

Nehru's suspicion of businessmen shaped as much by the European distrust of capitalism between the wars as by India's forced de industrialization by the British East India Company committed him to state control of prices, wages, and production, and to strict limits on foreign investment and trade.

Engaging efforts with experts from 47 IDFA member companies and cooperation from other parts of the dairy industry, the Food and Drug Administration (FDA) and state regulators, IDFA advocated for, among other things: reasonable regulations in the Pasteurized Milk Ordinance (PMO) that align the Interstate Milk Shippers program with the requirements of the Food Safety Modernization Act's (FSMA) Preventive Controls for Human Food (PCHF) rule; harmonizing the PMO with an FDA rule on higher fortification levels of vitamin D3 and requiring FDA to be more transparent in the determination of foreign country regulatory equivalence with the U.S. Grade «A» program.

«Under FDA regulations at 21 CFR part 111, all domestic and foreign companies that manufacture, package, label or hold dietary supplement, including those involved with testing, quality control, and dietary supplement distribution in the U.S., must comply with the Dietary Supplement Current Good Manufacturing Practices (CGMPs) for quality control.»

The law applies to companies that are owned or controlled by foreign governments.»

Even when foreign companies such as General Electric or Suzlon supply the turbines as much as 70 percent of the components are made in China, everything except for bearings and electrical controls.

But because of the Chinese government's concern about foreign control of China's seed industry, Pray says, officials have allowed the company to commercialize only one hybrid cultivar.

He has also started the process of nationalizing most of Bolivia's natural gas fields - in May this year, troops were sent to occupy the fields, taking back control from foreign companies (mainly Brazilian), which has led to an obvious strain in relations between the two countries.

As Philip Cercone notes, «Book publishing in Canada is not in the hands of, or controlled by Canadian - owned companies, but is in those of a very few profitable foreign - controlled book publishers.

A unique aspect of the Canadian book publishing market is that 19 foreign - controlled publishers, which represented less than 6 % of all companies surveyed, accounted for 59 % of domestic book sales in 2004 (the percentage has increased).

Here are some of ASIC «s concerns: many AFS license holders appeared to be based overseas, while promoting the security of Australian regulation; a number number of smaller licensed companies that were foreign - owned (or controlled by a foreign firm) showed lack of awareness or understanding of Australian regulations; some of the firms holding ASIC licenses had outsourced key compliance aspects to third parties, some of which were related to the AFS licensees and based overseas (and were subject to little, if any, regulatory oversight in their home jurisdiction).

State - controlled oil producer OAO Rosneft said it has paid back $ 7 billion of a bridge loan it had taken to acquire TNK - BP, the largest foreign debt repayment by a Russian company since Western sanctions were imposed.

The Montaka Global Offshore Fund, the Cayman Islands company into which the Montaka Global Fund will invest, will initially be classed as a Controlled Foreign Corporation (CFC) by the ATO and may pay annual distributions.

Loke had two money transfers stopped by The Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department; the deposits were being sent through the third - party payment processor, Counting House, a company that was blacklisted and defined by the U.S. Treasury as a criminal organization.

The U.S. Office of Foreign Assets Control has given Renova and other Russian companies until June 5th to «wind down operations, contracts, or other agreements» involving these figures.

One of the major provisions of the US Tax Reform forced large US companies like Apple and Google to pay a sizable tax on profits they held outside the US in their foreign subsidiaries (called CFC — controlled foreign corporations).

Representing public and private companies in internal investigations regarding such issues as Office of Foreign Assets Control (OFAC) compliance, premature revenue recognition, federal contract fraud, money laundering, immigration and I - 9 compliance, and employee embezzlement and theft.

In fact, 19 foreign - controlled publishers, who represented less than 6 % of all companies surveyed, accounted for 47 % of total revenues for the book publishers surveyed in 2004.

Revenues in Canada's book publishing industry exceeded $ 2 billion in 2004, and foreign - controlled companies accounted for almost half of the industry revenues, according to the latest data from a survey of book publishers.

We assist our clients operating in the international arena with a variety of tax issues that may arise in international and cross-border transactions, expansion of their U.S. businesses abroad, controlled foreign corporations and passive foreign investment companies, strategic alliances and joint ventures.

Section 2 (c) of the Act defines the term «International Commercial Arbitration» and it means an Arbitration relating to disputes arising out of legal relationships, whether contractual or not, considered as commercial under the law in force in Bangladesh and where at least one of the parties is: (i) an individual who is a national of or habitually resident in, any country other than Bangladesh; or (ii) a body corporate which is incorporated in any country other than Bangladesh; or (iii) a company or an association or a body of individuals whose central management and control is exercised in any country other than Bangladesh, or (iv) the Government of a foreign country.

Various instruments include a definition in which control over the enterprise invested in is most often the discriminating feature, setting foreign direct investment apart from a mere «portfolio investment», in which the investor does not exercise any direct influence on the management of the company in which the investment has been made.

Legislative proposals that would facilitate lawsuits against our fans or increase the labels» control over the enjoyment of music are made not in our names, but on behalf of the labels» foreign parent companies.