17 августа 2020
Екатерина Уцына
kantver / Depositphotos.com
В соответствии с нормами налогового законодательства внереализационными доходами налогоплательщика признаются доходы от долевого участия в других организациях, за исключением дохода, направляемого на оплату дополнительных акций (долей), размещаемых среди акционеров (участников) организации (п. 1 ст. 250 Налогового кодекса). Также к таким доходам относится и прибыль контролируемых иностранных компаний для налогоплательщиков — организаций, признаваемых контролирующими лицами этой иностранной компании (п. 25 ст. 250 НК РФ).
Вместе с тем, как поясняет налоговая служба, при определении налоговой базы не учитываются доходы, полученные налогоплательщиком — контролирующим лицом от контролируемой им иностранной компании в результате распределения прибыли этой компании. Пи этом, освобождение применяется, если доход в виде прибыли этой компании должен был указан этим налогоплательщиком в налоговой декларации (налоговых декларациях), представленной (представленных) за соответствующие налоговые периоды (письмо ФНС России от 12 августа 2020 г. № СД-4-3/12993@).
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Также должны выполняться и некоторые другие условия. Так, вышеуказанные доходы не учитываются при определении налоговой базы в сумме, не превышающей сумм дохода в виде прибыли контролируемой иностранной компании, указанных налогоплательщиком — российским контролирующим лицом в налоговой декларации (налоговых декларациях), представленной (представленных) за соответствующие налоговые периоды (подп. 53 п. 1 ст. 251 НК РФ).
При этом, как уточняет ФНС России, положений, устанавливающих суммовые ограничения для исчисления и уплаты налога на прибыль организаций с доходов от долевого участия, действующим законодательством Российской Федерации не предусмотрено.
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Javier Bardem has responded to the criticism over his being Spanish
and playing Cuban American actor Desi Arnaz.
The 52-year-old Oscar winner stars in the movie Being
The Ricardos opposite Nicole Kidman who plays sitcom icon Lucille Ball.
‘I’m an actor, and that’s what I do for a living: try to be people that I’m not,’
Javier told The Hollywood Reporter in a new interview.
Answering back: Javier Bardem has responded to the
criticism over his being Spanish and playing Cuban American actor
Desi Arnaz; seen last week in LA
Javier also argued that the flak over nationality tends to be aimed in particular
at non-native English speakers like himself.
‘What do we do with Marlon Brando playing Vito Corleone? What do we
do with Margaret Thatcher played by Meryl Streep? Daniel
Day-Lewis playing Lincoln? Why does this conversation happen with people with accents?’ he said.
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‘You have your accent. That’s where you belong. That’s
tricky. Where is that conversation with English-speaking people doing things
like The Last Duel, where they were supposed to be French people in the Middle Ages?
That’s fine. But me, with my Spanish accent, being Cuban?’
He added defiantly: ‘What I mean is, if we want to open the can of worms, let’s open it for everyone.
The role came to me, and one thing that I know for sure is
that I’m going to give everything that I have.’
Profession: ‘I’m an actor, and that’s what I do for a living: try to
be people that I’m not,’ Javier told The Hollywood Reporter; he is pictured as Desi
The husband of Penelope Cruz joked: ‘We should all start not allowing
anybody to play Hamlet unless they were born in Denmark.’
After his interview he emailed the publication and
qualified his earlier remarks: ‘I do recognize that there are many underrepresented voices and stories
that need to be told, and we should collectively do better to provide access and opportunities
for more American Latino stories and storytellers.’
As Javier was slated for playing a Latino despite not
being one, Rachel Zegler has received opprobrium for supposedly being the wrong
type of Latina to play Maria in West Side Story as she is of Colombian and Polish
descent rather than Puerto Rican.
Javier and Nicole were both controversial choices for their roles when they were cast as
Lucy and Desi, whose daughter Lucie Arnaz publicly defended Nicole.
Incoming: The 52-year-old Oscar winner stars in the movie Being The Ricardos opposite
Nicole Kidman who plays sitcom icon Lucille Ball
The blowback they received was so intense that they
both apparently tried to extricate themselves from the film as a result.
Although the producer Todd Black was able to persuade their agents to keep them in, Nicole and Javier still
wanted the film postponed a year.
Nicole said that once their attempts to finagle a delay were unsuccessful ‘then it was like: «Oh, no. Oh, no. We actually have to do this.»‘
Since both Nicole and Javier grew up abroad they were unaware of how proprietary Americans felt about Lucy and Desi and so were unprepared for the backlash.
There he is: The real Desi Arnaz, who had a turbulent marriage to Lucille that ended in divorce, is
pictured in 1954 during the run of I Love Lucy
Aaron himself has previously defended casting Javier in the midst of controversy
about his not being Latin American.
‘First of all, Amazon’s casting department had a Latina casting consultant on board.
I found out, for instance, because there was an actor who I was
considering who’s Brazilian, and I was told by the casting consultant that Brazilians aren’t considered [Hispanic] because they speak
Portuguese,’ he told the Hollywood Reporter.
‘So, Javier is Spanish and the casting consultant was fine with it.
But I don’t want to use the casting consultant
as cover. I want to tell you my opinion on this and I stand by it,
which is this: Spanish and Cuban aren’t actable, OK? They’re not actable. By the way, neither are straight and
gay,’ he added.
‘Because I know there’s a small movement underway
that only gay actors should play gay characters.
Gay and straight aren’t actable. You could act being attracted to someone, but most nouns aren’t actable.’
Film history: Javier argued: ‘What do we do with Margaret Thatcher played by Meryl Streep?’ asking:
‘Why does this conversation happen with people with accents?’
Meanwhile as rumors of Nicole’s casting began to spread this January it set of a swirl
of online chatter about who would be better suited for the role.
Debra Messing, who had just starred in a homage to I Love Lucy on the last season of
Will And Grace, began aggressively pitching herself for the part
on Twitter.
However Lucie posted a Facebook video urging fans to ‘stop arguing about
who should play it — she doesn’t look like her, her nose isn’t the same, she isn’t as funny.’
She noted that the film is ‘the story of Lucille Ball, my actual
mother, not Lucy Ricardo, and her husband Desi Arnaz, my dad, not Ricky Ricardo.’
New work: ‘Where is that conversation with English-speaking people
doing things like The Last Duel, where they were supposed to be French people in the Middle Ages?’ Javier asked
Desi, who played Lucy’s bandleader husband Ricky Ricardo on their program, had a tumultuous marriage to
her in real life.
She filed for divorce for the first time in 1944, reportedly over
his philandering and drinking, but they got back together
before splitting up permanently in 1960.
In the meantime they produced two children and the sitcom that etched them into TV legend, running from 1951 to 1957.
Throwback: Despite their divorce, in which she called
their marriage ‘a nightmare,’ Lucy and Desi remained publicly amicable
for the rest of his life; they are pictured while married
They also starred in movies together throughout their marriage, including Forever, Darling and the Vincente Minnelli comedy The Long, Long Trailer.
Despite their divorce, in which she called their marriage ‘a nightmare,’ Lucy and
Desi remained publicly amicable for the rest of his life.
Lucy married Borscht Belt comic Gary Morton in 1961
and stayed with him until her death in 1989, while Desi married one Edith Hirsch in 1963.
Edith and Desi both died of cancer one year apart — she passed on in 1985 and her husband, who loved cigars from
his native Cuba, succumbed to lung cancer in 1986.
Aaron Sorkin’s new biopic is about a single week
spent making an episode of I Love Lucy during which
Lucy and Desi’s marriage is shaken.
The turbulent week, reportedly running from the table read to the taping in front of
a studio audience, is said to include a professional landmine for
the couple as well.
Javier BardemNicole Kidman
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An obese fast food addict who would secretly binge on greasy takeaways has dropped an incredible 82kg and six dress sizes after switching to
a vegan diet.
In 2016, Kirsty Young, from Geelong, Victoria, said her self-esteem was at an all-time low when she tipped the scales at
167kg and wore size 26 clothing.
The now 34-year-old had an addiction to fast food and would often have secret mammoth
binges after stopping in at McDonald’s or KFC on the way home from work.
An obese fast food addict who would secretly binge on greasy takeaways has dropped an incredible
82kg and six dress sizes after switching to a vegan diet (pictured now)
In 2016, Kirsty Young, from Geelong, Victoria, said her self-esteem was at an all-time low
when she tipped the scales at 167kg and wore size 26 clothing
(left, in 2016, right, now)
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