The Resource Re Japanese taxation of Delaware Limited Partnership : 2013 (Gyo-Hi) No 166

Re Japanese taxation of Delaware Limited Partnership : 2013 (Gyo-Hi) No 166

Label
Re Japanese taxation of Delaware Limited Partnership : 2013 (Gyo-Hi) No 166
Title
Re Japanese taxation of Delaware Limited Partnership : 2013 (Gyo-Hi) No 166
Contributor
Subject
Language
eng
Summary
Judgment by the Supreme Court of Japan, judgment date 17 July 2015. The taxpayers invested in a business managed by a Delaware limited partnership which leased and ran apartments in the US. The taxpayers filed tax returns in which they claimed deductions from other income for losses incurred through investment in real property under art. 26 (1) of the Japanese Income Tax Act. The tax office disallowed the deductions on the basis that the investment was not in real property. The taxpayer appealed. The issue turned on whether a Delaware limited partnership was, for the purposes of Japanese tax law, a separate entity or was fiscally transparent so that its income was taxable directly in the hands of the investors
Citation source
In: International tax law reports. - London. - Vol. 18 (2015),
Language note
  • English
  • Japanese
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • entity classification
  • limited partnership
  • Delaware corporation
  • tax transparency
Label
Re Japanese taxation of Delaware Limited Partnership : 2013 (Gyo-Hi) No 166
Instantiates
Publication
Label
Re Japanese taxation of Delaware Limited Partnership : 2013 (Gyo-Hi) No 166
Publication

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