There has been some recent press regarding some of the procedural aspects of refund claims relating to foreign tax credits and they stand as a reminder about how significant the statute of limitations periods can be in processing tax claims. In a case decided last year on October 20, 2014,… – Continue reading
The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months, in particular in relation with double tax treaty conditions to benefit from a tax credit, abuse of law challenges, increased amortization rates, and priority preliminary ruling requests… – Continue reading
The first fiscal amendment of the Juan Carlos Varela government was passed earlier this month on May 4, by Law 27 of 2015. Here are two important pointers of the fiscal reform: 1. TAXABLE INCOME PRODUCED IN PANAMA Article 694 of the CF originally included as taxable income the income… – Continue reading
Many states in our nation suffer the effects of over-taxation. Whether it’s high state income taxes pushing families to seek brighter economic climates or high corporate taxes compelling businesses to relocate their headquarters, taxes play a huge role in how state economies function. One of the most contentious and potentially… – Continue reading
On May 18, the Supreme Court decided a Maryland case involving double taxation. Maryland’s tax code does not give full credit to residents who also pay taxes in states where they work. The Court sided with the taxpayers, and the decision may cost some states and cities millions of dollars…. – Continue reading
(Special) — The recent slump in oil prices is causing many Canadian investors to move their money from energy-weighted markets at home to foreign markets for better yields. While this may be a profitable investment strategy, it also can create its own set of problems because many investors may not… – Continue reading
Maryland’s taxation policy violated the U.S. Constitution by taxing income that state residents earned in other states, the U.S. Supreme Court ruled on Monday. The nation’s apex said the state’s controversial policy imposed form of double taxation on residents. The court in its ruling said Maryland cannot impose form of… – Continue reading
Chancellor George Osborne has announced that he intends to deliver a new budget on 8 July. In what will be the second budget within four months, Osborne is set to reveal how the Conservative government will cut £12bn from the welfare budget and “deliver on the commitments we have made… – Continue reading
There’s more trouble for Indians holding undeclared assets overseas as the black money bill passed by the Lok Sabha on Monday will disallow foreign tax credits, cutting off another loophole, reports the Economic Times. Holders of such assets that are not declared within the stipulated period will be denied credits… – Continue reading
Deloitte managing tax partner Thomas Pippos says the IRD are using electronic payments and websites to pursue tax cheats Budget-conscious tax collectors are increasingly turning to popular websites and other e-channels to chase undeclared taxable income, a top accountant says. Inland Revenue Department no longer had capacity or interest in… – Continue reading
OTTAWA —The Liberal plan for the middle class, two planks of which were unveiled this week, could risk another brain drain in Canada, stalling the national economy, says one public policy and economics expert. “It’s a real possibility,” said Charles Lammam, director of fiscal studies at the right-leaning think tank… – Continue reading
The American Chamber of Commerce has warned that new Irish tax incentives may fail because they do not match the needs of multinationals, reports the Irish News. The chamber, which represents 700 US companies, has said the forthcoming Knowledge Development Box – which will replace the discredited Double Irish structure… – Continue reading
The IRS, the most powerful and least accountable agency of the federal government, is an admitted criminal enterprise. To deal with this, Republican candidates for president are placing tax reform at the top of their agendas. You will have to guess why the Democrats seem not to care. Sen. Ted… – Continue reading
The patent box regime, adopted at the end of 2014 with Italy’s Stability Law, was recently modified by the Investment Compact Decree and implemented into law at the end of March 2015. A distinctive feature of the Italian regime is that the measure now also covers trademarks and designs. A… – Continue reading
Chapter 3 of the Internal Revenue Code requires payors (and recipients) of certain types of U.S. source income to withhold tax if the beneficial owner or recipient is a non-U.S. person for income tax purposes. Chapter 4 also imposes similar withholding under FATCA for payments to foreign financial institutions and… – Continue reading
In October 2013 Minister Michael Noonan presented Budget 2014. The Minister’s budget speech indicated that one of the primary aims of that Budget was to bring Ireland back to a position where it could fund itself fully through the international markets in a sustainable way, at competitive interest rates. It… – Continue reading
During 2014, Barbados again produced strong evidence of the underlying strength of its financial system. All of the financial stability indicators and stress tests performed for the financial system strongly indicate that the system remains stable with the capacity to withstand a wide variety of severe economic shocks. It is… – Continue reading
FORMER treasurer Peter Costello says changing or ending tax credits for shareholders who get dividends would see investors send their money offshore. The financial system inquiry (FSI) last year questioned the wisdom of dividend imputations, where shareholders get a tax credit for the profits a firm shares with investors via… – Continue reading
The Tax Office is cracking down on what it’s described as “contrived arrangements” that allow hundreds of wealthy individuals with self-managed superannuation funds (SMSFs) to pay no tax on income from shares. Cases are still being reviewed and it’s unclear how much tax revenue may be at stake. But the… – Continue reading
Ontario’s 2015 Budget, delivered on April 23, overhauled a number of the province’s tax credits and set out plans for a further crackdown on tax avoidance. The Budget made numerous changes to creative tax breaks, effective from April 23, 2015. The Ontario Production Services Tax Credit was reduced from 25… – Continue reading
David Cameron says he will press on with welfare reforms after Miliband’s earlier claim Tories have plan for cuts to tax credits that would devastate family finances David Cameron declined an opportunity to rule out imposing further cuts to tax credits in the next parliament an hour after Labour accused… – Continue reading
According to the most recent estimates, the quantity of goods carried by containers has risen from around 100 million metric tons in 1980 to about 1.5 billion metric tons in 2012. Out of these numbers, one container in every 11 that is engaged in global trade is either bound for… – Continue reading
The Shareholders Association is making “strenuous representations” to the Inland Revenue Department over what it says is an unfair tax facing possibly thousands of New Zealand investors as a result of a proposed demerger of Anglo-Australian mining giant BHP Billiton. In an effort to simplify its business, Melbourne-based BHP is… – Continue reading
Vermont Sen. Bernie Sanders introduced a corporate tax bill earlier this month. Unsurprisingly, it cuts in a different direction than most tax proposals floating around Washington these days. The bill (S.922) is titled the Corporate Tax Dodging Prevention Act of 2015. A companion bill was introduced in the House by… – Continue reading
NUMBER OF THE WEEK: 6.5 percent The tax rate at which companies could voluntarily repatriate their foreign earnings under the Invest in Transportation Act of 2015 ( S. 981). Senators Barbara Boxer (D-CA) and Rand Paul (R-KY) introduced the bipartisan proposal, offering ways to save the Highway Trust Fund. Funding… – Continue reading
Switzerland is to amend federal tax legislation to prevent the double taxation of certain permanent establishments (PEs) located in the country. The planned reform is the result of a consultation on the application of the flat-rate tax credit. It will affect PEs in Switzerland that have their registered office in… – Continue reading
During an April 22 hearing of the US House of Representatives Ways and Means Subcommittee on Oversight, Republican lawmakers raised concerns at issues arising during the 2015 tax filing season and the service offered by the Internal Revenue Service. On the day of the hearing, the Republican-led Ways and Means… – Continue reading
The Minister of Finance (Canada), the Honourable Joe Oliver, presented the Government of Canada’s 2015 Federal Budget (“Budget 2015”) on April 21, 2015 (“Budget Day”). Budget 2015 contains several significant proposals to amend the Income Tax Act (Canada) (the “ITA”) while also providing updates on previously announced tax measures and… – Continue reading
Minister of Finance Joe Oliver today tabled the 2015 Federal Budget (the “Budget”), his first budget as Minister of Finance, entitled “Strong Leadership: A Balanced-Budget, Low-Tax Plan for Jobs, Growth and Security”. We are pleased to provide our summary of tax measures contained in the Budget. The Budget proposed no… – Continue reading
San Francisco, California – The United States filed a complaint to bar a San Francisco enrolled agent and tax return preparer from implementing, facilitating and promoting allegedly abusive tax shelters and tax avoidance schemes, the Justice Department announced today. According to the complaint, which was filed in the U.S. District… – Continue reading
Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading
The OECD Mutual Agreement Procedure Statistics for 20131 (MAP Statistics), released on November 25, 2014, show a dramatic surge in the inventory of mutual agreement procedure (MAP) cases among OECD member countries. The MAP Statistics confirm that the potential for double taxation is increasing. This is reflected most starkly in… – Continue reading
Australia’s $29 billion system of franking credits for investors is skewed heavily to the rich and is ripping a hole in the budget, a new analysis has found, with one tax break found nowhere else in the world costing almost $5 billion a year. Millions of Australians benefit from franking… – Continue reading
The government’s recent steps to check the flow of unaccounted wealth to foreign assets and bank accounts have had the unintended result of making tax compliance tough for expatriates on corporate assignments here, who have legitimate assets in their home countries, say experts. The tax troubles of these people over… – Continue reading
Technology companies with international operations are increasingly using global tax avoidance methods, despite growing opposition from the public and politicians in the U.S. and abroad. As this opposition fuels ongoing changes in tax rules, organizations must be able to quickly adapt their corporate structures and tax strategies to maintain a… – Continue reading
BATON ROUGE – As they look for ways to solve next year’s budget problems, Louisiana lawmakers are getting a crash course in the state’s tax system: the loopholes they’ve created, the tax cuts they’ve given and the price tag for the myriad of tax breaks they’ve approved. Now, Democrats and… – Continue reading
World-Herald Bureau WASHINGTON — Nebraska rancher John McFadden will be watching this week as the House votes on eliminating the federal estate tax that could affect how much of his 500-head cattle operation he leaves to his children. McFadden saw much of his grandfather’s land sold off to pay taxes… – Continue reading
When Hillary Clinton recently borrowed Elizabeth Warren’s talking points and claimed “the deck is still stacked in favor of those at the top” (in our economic and political system) against regular working people, did she mention reforming the tax code — and then offer any solutions? The simple answer is… – Continue reading
Tax directors at many organizations anticipate their companies will grow by entering into new domestic and international markets in the years ahead, according to a new survey by BDO USA. In a sign of an improving economy, 50 percent of the 100 tax directors at $1billion-plus public companies surveyed by… – Continue reading
As the above title indicates (it is only a modest exaggeration), the Treasury Greenbook regarding the FY 2016 budget proposes a radical restructuring of the system for U.S. taxation of foreign income of U.S. multinational enterprises (MNEs). Some Congressional players have suggested that these proposals are an opening bid in… – Continue reading
Sen. Bernie Sanders (I-VT) drops a bomb on corporations who are dodging taxes by hiding money overseas by introducing new legislation that will force tax dodgers to pay their fair share. Here is part of what The Corporate Tax Dodging Prevention Act of 2015 would do: 1. Ending the rule… – Continue reading
The Internal Revenue Service (IRS) has reminded American citizens and resident aliens, including those with dual citizenship, who have lived or worked abroad during all or part of 2014 that they may have a US tax liability and a filing requirement in 2015. The agency pointed out that a filing… – Continue reading
– Rising Cost of Compliance Within The Tax And Financial Regulatory Environment Creates Opportunities For Increased Efficiency – CHICAGO–(BUSINESS WIRE)–As the economy continues to accelerate, many organizations plan to grow by entering into new markets in the years ahead, reveals the first ever BDO USA, LLP Tax Outlook Survey. Fifty… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins Canada is a federal state, with legislative powers divided between the federal and provincial governments. The federal government has legislative jurisdiction over issues concerning Canada as a whole, including foreign affairs, international trade, banking, telecommunications,… – Continue reading
Jury selection began today in federal court in New Orleans for the trial of Seven Arts Entertainment founder Peter Hoffman and two others accused of defrauding Louisiana’s film incentive program. Hoffman, his ex-wife and producer Susan Hoffman, and actor and film producer Michael Arata were indicted last year for conspiring… – Continue reading
Maryland officials are bracing for a Supreme Court decision this spring that could find a provision of the state’s income tax law unconstitutional, leaving the state and its counties on the hook for as much as $200 million in refunds and facing significant cuts in revenue. Montgomery County stands to… – Continue reading
The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX… – Continue reading
Australia is one of a handful of countries that offers franking credits, making the nation’s investors the envy of their counterparts elsewhere in the world. A franking credit is an income tax credit that companies can pass on to their shareholders. It is the result of dividend imputation, or attribution…. – Continue reading
The state Division of Taxation is taking steps to recoup $1.6 million in rebates it overpaid nearly 3,800 taxpayers, following an investigation by the Office of the State Comptroller. The comptroller’s office released the findings of its investigation into property tax relief programs for multi-unit properties Thursday along with steps… – Continue reading
