Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Asset disclosure for prospective attachment may be ordered from the commencement of foreign proceedings where the period is undisputed; disclosure identifies assets and does not decide whether they are attachable. Certified foreign judgments carry a mandatory presumption of competent jurisdiction under the CPC, which must be rebutted by credible evidence rather than disagreement with findings or bare reliance on statutory exceptions. Prior anti-enforcement proceedings and findings concerning diversion of assets supported the disclosure and restraint directions. Appellate intervention in interlocutory discretion is limited to arbitrary, capricious, perverse, or legally erroneous exercises of discretion; a reasonably possible first-instance view should not be replaced. The disclosure and restraint directions were maintained and the appeal dismissed.
Asset disclosure for prospective attachment may be ordered from the commencement of foreign proceedings where the period is undisputed; disclosure identifies assets and does not decide whether they are attachable. Certified foreign judgments carry a mandatory presumption of competent jurisdiction under the CPC, which must be rebutted by credible evidence rather than disagreement with findings or bare reliance on statutory exceptions. Prior anti-enforcement proceedings and findings concerning diversion of assets supported the disclosure and restraint directions. Appellate intervention in interlocutory discretion is limited to arbitrary, capricious, perverse, or legally erroneous exercises of discretion; a reasonably possible first-instance view should not be replaced. The disclosure and restraint directions were maintained and the appeal dismissed.
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