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schädliche Passiveinkünfte

English translation: adverse passive income

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GLOSSARY ENTRY (DERIVED FROM QUESTION BELOW)
German term or phrase:schädliche Passiveinkünfte
English translation:adverse passive income
Entered by: Davorka Grgic
Options:
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06:04 Feb 16, 2001
German to English translations [PRO]
Bus/Financial - Law: Taxation & Customs
German term or phrase: schädliche Passiveinkünfte
"Der Tätigkeitsschwerpunkt der ausländischen Gesellschaft besteht darin, Einnahmen aus Management und Consultingtätigkeiten zu erzielen. Einnahmen aus Zinsen, ... werden nicht erzielt. Demnach ist der Missbrauchsgrund der schädlichen Passiveinkünfte nicht erfüllt"
I don't know how to translate "schädlich" in this context.
Thanks for your help in advance.
MargitH
Local time: 01:07
adverse passive income
Explanation:
1. ADVERSE
Royalty income can be ADVERSE for personal holding company status and PASSIVE INVESTMENT INCOME of S corporation. ...

www.twise.com/writings/hightechtax.htm

It can also be translated as:

2. DETRIMENTAL
Income that would be subject to taxation, however, is not as narrow as would be expected from the characterization in the proposal of "investment income" but includes all "passive" income such as rent, royalties, interest, dividends, and capital gains.

/www.asaenet.org/newsroom/archives/0,1987,showarticle=yes^ar...

The branch is not likely to be paying foreign tax on this PASSIVE INCOME, and even if the taxpayer’s foreign business operations have generated excess foreign tax credits, those credits will not be available here because of the basket limitations that apply to the use of foreign tax credits.

Foreign subsidiary. If the funded plan is sponsored by a foreign subsidiary of the U.S. multinational, the potential consequences are more complicated, but no less DETRIMENTAL.
www.millerchevalier.com/public_library/IRS_Attack.html

Good luck.

Davorka
Selected response from:

Davorka Grgic
Local time: 01:07
Grading comment
Thank you to all of you for your help!
I used "adverse passive income" so the grade should really go to the third answerer as well. Unfortunately, I have to pick one.
Thanks again.
4 KudoZ points were awarded for this answer

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Summary of answers provided
naadverse passive income
Andy Lemminger
naadverse passive income
Davorka Grgic
naloss-making passive income
Mats Wiman


  

Answers


2 hrs
loss-making passive income


Explanation:
'schädlich'=detrimental, loss-making
'passive' in this context probably means interest-free


    Gabler Wirtschaftlexikon+MW
Mats Wiman
Sweden
Local time: 01:07
Native speaker of: Native in SwedishSwedish
PRO pts in category: 4

Peer comments on this answer (and responses from the answerer)
Andy Lemminger

profile removed

Ulrike Lieder
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2 hrs
adverse passive income


Explanation:
1. ADVERSE
Royalty income can be ADVERSE for personal holding company status and PASSIVE INVESTMENT INCOME of S corporation. ...

www.twise.com/writings/hightechtax.htm

It can also be translated as:

2. DETRIMENTAL
Income that would be subject to taxation, however, is not as narrow as would be expected from the characterization in the proposal of "investment income" but includes all "passive" income such as rent, royalties, interest, dividends, and capital gains.

/www.asaenet.org/newsroom/archives/0,1987,showarticle=yes^ar...

The branch is not likely to be paying foreign tax on this PASSIVE INCOME, and even if the taxpayer’s foreign business operations have generated excess foreign tax credits, those credits will not be available here because of the basket limitations that apply to the use of foreign tax credits.

Foreign subsidiary. If the funded plan is sponsored by a foreign subsidiary of the U.S. multinational, the potential consequences are more complicated, but no less DETRIMENTAL.
www.millerchevalier.com/public_library/IRS_Attack.html

Good luck.

Davorka


    Reference: http://europa.eu.int/eurodicautom/
    web
Davorka Grgic
Local time: 01:07
Native speaker of: Native in CroatianCroatian, Native in SpanishSpanish
Grading comment
Thank you to all of you for your help!
I used "adverse passive income" so the grade should really go to the third answerer as well. Unfortunately, I have to pick one.
Thanks again.

Peer comments on this answer (and responses from the answerer)
profile removed
Login to enter a peer comment (or grade)

9 hrs
adverse passive income


Explanation:
Just to explain this term: Schädlich means that the company isn't earning its income with active business operations (e.g. production of goods) but in a passive kind of way (e.g. royalties of a holding). This is "schädlich" only for tax reasons because such a company cannot be recognized in consolidated tax statements according to German law if it has a net loss.


    Work as public accountant and studies
Andy Lemminger
Canada
Local time: 17:07
Native speaker of: German
PRO pts in category: 24
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Changes made by editors
Dec 5, 2016 - Changes made by Steffen Walter:
FieldLaw/Patents » Bus/Financial


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