Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Property of equivalent value may be provisionally attached where property directly or indirectly derived from criminal activity is unavailable because it has vanished or been laundered. The phrase "or the value of any such property" operates as an independent limb of the definition of proceeds of crime, permitting attachment of substitute assets of equivalent value. Such assets may include property acquired before the alleged criminal activity and need not have a direct nexus with that activity. Restricting attachment only to directly traceable proceeds would render the equivalent-value limb ineffective and undermine the statutory objective.
Property of equivalent value may be provisionally attached where property directly or indirectly derived from criminal activity is unavailable because it has vanished or been laundered. The phrase "or the value of any such property" operates as an independent limb of the definition of proceeds of crime, permitting attachment of substitute assets of equivalent value. Such assets may include property acquired before the alleged criminal activity and need not have a direct nexus with that activity. Restricting attachment only to directly traceable proceeds would render the equivalent-value limb ineffective and undermine the statutory objective.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
