Archive for October 25th, 2010

Limitations to the deduction of Japanese partnership losses

October 25, 2010  |  Nin i Kumiai  |  No Comments

An attractive abstract picture of suckers on a boiled octopus, a healthy addition to the Japanese family table.

The Japanese tax law concerning Japanese civil law partnerships (in Japanese nin’i kumiai and below ‘NKs’) includes anti-avoidance provisions that can apply to deny the deduction of tax losses arising from an NK under circumstances where, generally speaking, the investment is passive and there are actual or substantive limits to the NK investor’s economic exposure to the underlying NK investments. Read More