Comentários ao Processo nº 16327.001170/2006-62 do CARF
| Autor | Pontieri |
Imposto sobre a renda de pessoa jurídica – IRPJ. Exercício de 2003. Lucros auferidos no exterior. Conversão para reais. CSLL. Equivalência patrimonial. Taxa de Câmbio. Variação Cambial: O Conselheiro Relator, Dr. Antonio Carlos Guidoni Filho, proferiu seu voto com o entendimento de que o paradigma apresentado pela Fazenda Nacional em seu recurso acabou por “enfrentar” apenas um único ponto do acórdão recorrido, principalmente quanto a questão da taxa de câmbio.
Para o relator, seria necessário “superar-se” inicialmente os...
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