Category: Tax Refunds

Canada / Double Taxation / Income Tax / Income Tax Act / Mutual Agreement Procedure / Profit Shifting / Tax Planning / Tax Refunds / Transfer pricing

Canada: Transfer Pricing: What’s New In Canada (Part II)

Published by: mondaq - September 4, 2019

Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals.  Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - Continue reading

Dividends / Income Tax / IRS / Jurisdiction / Starr International Company / Statute of Limitation / Switzerland / Tax Dispute / Tax Refunds / USA / Withholding tax rules

Swiss Taxpayer Wins US Tax Treaty Refund Dispute

Posted On: February 6, 2018

The United States District Court for the District of Columbia on January 31 ruled in favor of Starr International Company in a case concerning an erroneous refund paid to the taxpayer, which the IRS sought to reclaim. In 2011, the IRS erroneously issued a USD21m refund to Starr International Company,… – Continue reading

Income Tax / India / Interest / Legislation / Loans / Residence / Tax Deductions / Tax Refunds / Visa

10 ways you stand to gain from filing income tax return

Posted On: April 17, 2017

Filing of your income tax return (ITR) is mandatory under the Income Tax Act, 1961 under certain circumstances. For instance, if someone’s income exceeds the maximum amount not chargeable to tax, one is required to file income tax return.  Similarly, filing ITR is mandatory for ordinary residents having overseas assets… – Continue reading

Citizenship / Double Tax Avoidance Treaty / Individuals / Ireland / Residence / Switzerland / Tax Authority / Tax Refunds / USA

Irish Citizen Denied US Tax Refund On Gambling Winnings

Posted On: March 6, 2017

The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading

Budget / Business / Capital Gains Tax / Double Taxation / DTA / EU / Income Tax Act / Individuals / Intellectual Property / Interest / Jurisdiction / Legislation / Malta / Music / Royalties / Tax Credit / Tax Exempt / Tax Refunds

Tax benefits of using Malta as an IP regime

Posted On: November 28, 2016

For myriad reasons, Malta has over the years established itself as an ideal jurisdiction to hold intellectual property rights. The country offers many tax benefits on income derived from Intellectual Property. Apart from the tax exemption on income derived from patents, copyrights and trademarks as will be further explained below,… – Continue reading

Banking / Banking Secrecy / Finland / Individuals / Legislation / Offshore Fund / Switzerland / Tax evasion investigations / Tax Fraud / Tax Refunds / USA

Taxman sets police on Finns coming clean on undeclared overseas income

Posted On: November 13, 2016

Finns alarmed by cracks in the previously iron-clad Swiss banking secrecy have come forward to volunteer information about undeclared overseas income to Finnish tax authorities. They were hoping for immunity from fines or criminal sanctions but dozens now face police investigations. The Finnish Tax Administration has requested police investigations into… – Continue reading

Education / Income Tax / IRS / Mexico / Revenue / Tax Refunds / Withholding Tax

New Mexico settles lawsuit over immigrant tax refunds

Posted On: October 28, 2016

The New Mexico tax department has agreed to stop automatically withholding income tax refunds from many foreign nationals without Social Security numbers who file under alternative identification numbers provided by the IRS, a New Mexico state senator said Friday. Sen. Gerald Ortiz y Pino said he co-signed the settlement as… – Continue reading

Double Tax Avoidance Treaty / Estonia / Finland / Industrial / Royalties / Tax Authority / Tax Avoidance / Tax Refunds / Tax treaties / Withholding Tax

Finnish Royalties To Estonia No Longer Taxed

Posted On: October 5, 2016

The Finnish Tax Administration has confirmed that the payment of Finnish-sourced royalties to taxpayers in Estonia are not subject to withholding tax under the Finland’s double tax avoidance treaty with the Baltic state. In a tax administration bulletin issued on October 3, the Finnish tax authority said that as of… – Continue reading

Internal Revenue Service (IRS) / Offshore / Tax Avoidance / Tax Credit / Tax evasion investigations / Tax Refunds / USA / Voluntary Disclosure Program

IRS Releases Dirty Dozen Scam List: Don’t be a Victim

Posted On: February 23, 2016

Each year, people fall prey to tax scams. That’s why the IRS sends a list of its annual “Dirty Dozen.” Stay safe and be informed – don’t become a victim. If you get involved in illegal tax scams, you can lose money or face stiff penalties, interest and even criminal… – Continue reading

Africa / Banking / Capital gains / Corporates / IMF / Individuals / Investments / Mozambique / Norway / Oil / PWC / Revenue Recovery Charge (RRC) / South Africa / Stamp Duty / Tax Laws / Tax Refunds / VAT / Withholding tax rules

Can new guidelines get Nigerians into tax net?

Posted On: January 24, 2016

The Federal Inland Revenue Service (FIRS) which is now saddled with the onerous task of getting alternative sources of revenue for the federal government has since adopted a stick and carrot approach to bringing tax payers into the tax net. Assistant Editor, Nduka Chiejina looks at the issues contained in… – Continue reading

Asia / Bonds / Double Taxation / Europe / European Commission / Financial markets / Residence / Tax Refunds / USA / Withholding tax rules

Exclusive: EU plans faster investment tax refunds from 2017 – document

Posted On: January 20, 2016

European Union countries will have to introduce rules from 2017 to speed up tax refunds on cross-border investments, part of a drive to improve the working of financial markets and lift economic growth, according to an EU document seen by Reuters. The executive European Commission wants to simplify “withholding tax”… – Continue reading

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