Comentários ao Processo: 16327.001171/2006-15 do CARF
| Autor | Alexandre Pontieri |
Recorrente: Fazenda Nacional
Recorrido: Contribuinte
Ementa da Decisão recorrida: “EQUIVALÊNCIA PATRIMONIAL - VARIAÇÃO CAMBIAL - INVESTIMENTOS NO EXTERIOR -Tendo em vista as razões contidas na da mensagem de veto ao artigo 46 do projeto de conversão da MP 135/2003, a variação cambial de investimento no exterior, contida no ajuste de valor por equivalência patrimonial, não constitui nem despesa dedutível nem receita tributável, indicando necessidade de lei expressa nesse sentido.
LUCROS AUFERIDOS POR COLIGADA NO EXTERIOR - VARIAÇÕES CAMBIAIS.
Os lucros auferidos por coligada no exterior serão convertidos em Reais pela taxa de câmbio, para venda, do dia das demonstrações financeiras em que tenham sido apurados os referidos lucros, a teor do § 40 do art. 25 da Lei n° 9.249/95.
CSLL - LUCROS AUFERIDOS NO EXTERIOR - 1RRETROATIVIDADE DA NORMA TRIBUTÁRIA. O artigo 19 da Medida Provisória n°...
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