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Taxpayer Appeals Loss in Rare Constitutional Challenge to Composite Return Statute
Bradley Arant Boult Cummings LLP, September 2020

Cases challenging the constitutionality of state pass-through entity (PTE) nonresident owner withholding or composite return statutes are extremely rare. However, a recent Alabama Circuit Court decision, Black Eagle Minerals, LLC v. Alabama Department of Revenue, Case No. CV-2018-900328.00 (Cir. Ct. Montgomery County, Ala., July 27, 2020), highlights why such challenges may be more common when PTE composite returns are mandatory...

GAO Report on Abusive Tax Schemes Perpetuates Misunderstandings of Captives
Bradley Arant Boult Cummings LLP, September 2020

A GAO report was intended to shed some light the use of captives as abusive tax shelters. Instead it only risks perpetuating misunderstandings, says Bradley’s Davis Smith...

Executive Order Payroll Tax Deferral: Guidance and Considerations
Buchalter, September 2020

On August 8, 2020, the President of the United States issued a Presidential Memorandum directing the Secretary of the Treasury to use his authority pursuant to section 7508A of the Internal Revenue Code to defer the withholding, deposit, and payment of certain payroll tax obligations for the remainder of 2020. In Notice 2020-65, the IRS provides guidance implementing the payroll tax deferral.  What wages are eligible?  Eligibility is subject to income limits...

Deferring Payroll Tax—The IRS Lets Employers Off The Hook
Dykema, September 2020

On September 2, 2020, we issued an e-alert discussing the deferral of the employee portion of Social Security taxes (“SS Tax Deferral Program”), as directed by the Presidential Memorandum dated August 28, 2020, and as implemented by the Internal Revenue Service (“IRS”) pursuant to Notice 2020-65 (“Notice”) issued on August 28, 2020...

Shearn Delamore & Co. Legal Update August 2020 (Tax and Revenue)
Shearn Delamore & Co., September 2020

Income tax The following public rulings and guidelines have recently been published on the Inland Revenue Board of Malaysia’s official website: i. Tax Treatment of Research and Development Expenditure Part I – Qualifying Research and Development Activity (Public Ruling No. 5/2020) issued on 13 August 2020; ii. Tax Treatment of Research and Development Expenditure Part II – Special Deductions (Public Ruling No. 6/2020) issued on 13 August 2020; iii...

Deferring Payroll Tax—The Employer’s Dilemma
Dykema, September 2020

On August 13, 2020, President Trump issued a Presidential Memorandum directing the Secretary of the Treasury to use his authority to defer the withholding, deposit and payment of the employee portion of Social Security taxes (“SS Tax Deferral Program”). On August 28, 2020, the Secretary of the Treasury and IRS issued Notice 2020-65 (“Notice”) to implement the SS Tax Deferral Program...

What Employers Need to Know About the Payroll Tax Deferral Guidance
Bradley Arant Boult Cummings LLP, September 2020

Following President Trump’s Aug. 8 presidential memorandum directing the Treasury Secretary to defer the withholding and payment of certain employee payroll taxes, the Internal Revenue Service released Notice 2020-65 on Aug. 28 The two-page notice gives necessary but sparse guidance on implementing the Presidential Memorandum...

Special Regimes Relevant to Panamanian Startups
Morgan & Morgan, September 2020

At the beginning of astartup’slife,the use of financial resources in the most efficient way is of vital importance.It is for this reasonthatthe incentives that a country can provide to an entrepreneurand hisnewlyformed company can potentially determine how and how much that company willgrow...

COVID-19 Payroll Tax Notice from the IRS Offers Sparse Guidance
Bradley Arant Boult Cummings LLP, August 2020

Following the August 8, 2020 Presidential Memorandum directing the Treasury Secretary to defer the withholding, deposit, and payment of certain payroll taxes, the Internal Revenue Service released Notice 2020-65 late Friday, August 28. The brief notice gives necessary but sparse guidance on implementing the Presidential Memorandum. We expect (and hope for) further guidance soon...

IRS Issues Last-Minute Guidance on Deferral of Employees' Social Security Withholding
Hanson Bridgett LLP, August 2020

Key Points Employers can, but are not required to, delay withholding and paying the employee portion of Social Security taxes for certain employees until Jan. 1, 2021. The deferral only applies to Social Security taxes due from Sept. 1, 2020, to Dec. 31, 2020, by employees who earn less than $4,000 in a bi-weekly pay period. From Jan. 1, 2021 through Apr...

IRS Offers Guidance on Implementing Elective Employee Social Security Tax Deferral
Dinsmore & Shohl LLP, August 2020

On Aug. 28, 2020, the U.S. Department of Treasury and the Internal Revenue Service (IRS) issued Notice 2020-65 (the Notice). The Notice implements President Donald Trump’s Aug. 8, 2020 directive (the Directive) to defer withholding, deposit, and payment of the 6.2 percent employee share of Social Security tax and railroad retirement equivalent tax on certain wages and compensation paid to employees...

Congress Approves Bill that Establishes Tax Measures to Reactivate the Economy
Carey, August 2020

On August 18, the Chamber of Deputies and the Senate approved a bill introduced by the government on June 25, which establishes the emergency plan to promote economic recovery and employment. Although in its first phase, the project was modified and approved by the Chamber of Deputies, and rejected by the Senate, the new proposal submitted by the Joint Commission was approved in its entirety by the Congress...

Congress Approves a Bill that Includes an Instant Depreciation Regime for Intangible Assets Consisting of Industrial and Intellectual Property Rights or a New Plant Variety
Carey, August 2020

On Tuesday, August 18, the Congress approved a bill that contemplates several tax measures in order to inject liquidity and promote economic reactivation (the "Bill"). Among other measures, the Bill grants the possibility to Corporate Tax taxpayers who declare effective income according to complete accounting, to instantly depreciate 100% of the value of new or imported fixed assets acquired between June 1, 2020 and December 31, 2022...

Coronavirus: Recent Tax Measures to Support Micro, Small and Medium-Sized Enterprises
PLMJ, August 2020

A major economic crisis has been caused by the pandemic associated with the new SARS-CoV-2 Coronavirus and the COVID-19 disease. In this context, Law 29/2020 was published on 31 July to establish new tax measures to support cooperatives, micro, small and medium-sized enterprises. The aim of these measures it to mitigate the impacts of the pandemic on these businesses...

Social and Economic Emergency Plan for the Algarve
PLMJ, August 2020

The Algarve has been seriously affected by the social and economic impacts of the COVID-19 pandemic. In this context, on 29 July 2020, the Portuguese Parliament published Resolution no. 51/2020 in which it recommend the adoption of a social and economic emergency plan for the Algarve (“Plano de emergência social e económico para o Algarve”) by the Portuguese Government. The recommended measures set out in Resolution no...

Kochhar & Co. Tax Newsletter - Chennai Tribunal, Holds Loan Foreclosure Charges not Subject to Service Tax
Kochhar & Co. Advocates & Legal Consultants, August 2020

This tax newsletter summarises the recent ruling of CESTAT, Chennai in the case of Commissioner of Service Tax, Chennai vs M/ Repco Home Finance Limited on non - applicability of Service tax on loan foreclosure charges...

COVID-19 “Safe Harbour” Not for Sinking Ships
MinterEllisonRuddWatts, August 2020

Director’s personal liability for company tax debts On 10 July 2020, Inland Revenue issued a public ruling (the Ruling) considering the application of the asset stripping rules (under which directors and shareholders may be personally liable for company tax debts) in the context of the recently enacted exception to certain directors’ duties under the Companies Act 1993 (the Safe Harbour)...

Persistence Pays Off in Sale of Idaho Pass-Through Entity
Bradley Arant Boult Cummings LLP, July 2020

Retired Navy SEALs apparently have a persistence that other taxpayers may not have. Case in point (literally)—Noell Industries, Inc. v. Idaho State Tax Commission, decided on May 22, 2020, by the Idaho Supreme Court...

Shearn Delamore & Co. Legal Update July 2020 (Tax and Revenue)
Shearn Delamore & Co., July 2020

Tax and Revenue Income tax The following technical guidelines have recently been published on the Inland Revenue Board of Malaysia’s official website: Garis Panduan Mengenai Duti Setem ke atas Suratcara Pindah Milik Saham bagi Saham dalam Syarikat yang Tidak Tersenarai di Bursa Malaysia Berhad (available in Malay language only) — issued on 23 June 2020 to replace Technical Guideline dated 6 November 2019;Garis Panduan Permohonan untuk Kelulusan Ketua Pengarah Hasil Dal

Greater Bay Area introduces new Individual Income Tax incentives to attract foreign talent
Deacons, July 2020

In an effort to attract more foreign talent to work in the Guangdong-Hong Kong-Macau Greater Bay Area (GBA), the Ministry of Finance and State Administration of Taxation jointly issued a Notice on 14 March 2019, granting Individual Income Tax (IIT) subsidy to overseas (including Hong Kong, Macau and Taiwan) high-end talent and talent in short supply working in the GBA (Circular 31)...

IRS Issues Guidance on 2020 Waiver of Required Minimum Distributions
Hanson Bridgett LLP, July 2020

Key Points Participants in defined contribution retirement plans, such as 401(k), 401(a), 403(b), or governmental 457(b) plans, can skip their required minimum distribution (RMD) payments for 2020. If RMDs for 2020 have already been received, participants have until August 31, 2020 to rollover the RMD into an eligible retirement plan...

Client Bulletin No. 27 (Updates on COVID-19 related PH Issuances): Recent Issuances by the IPOPHL and the BIR
SyCip Salazar Hernandez & Gatmaitan, July 2020

This is a briefing on the issuances as of July 22, 2020 on the following matters in relation to the COVID-19 pandemic: A. Intellectual Property Office (IPOPHL) Suspends Services at its Main Office from July 20 to 27, and Extends Deadlines B. BIR Amends Reportorial Requirements of Banks and Other Lenders that Granted a Grace Period on Loans that were due during the Enhanced Community Quarantine C. New Bureau of Internal Revenue (BIR) Form for Related Party Transactions   A...

Extension of Deadlines to Perform Transfer Pricing Obligations
Wardynski & Partners, July 2020

“Shield 4.0” extends the deadlines for all obligated entities to file transfer pricing information (TPR), declarations on preparation of local transfer pricing documentation, and enclosures of group transfer pricing documentation. The earlier regulations extended the deadlines only for selected taxpayers...

Resolution No. 61/202 of Chilean Tax Authority Amends Instructions on Certificate No. 66 on Donations / Supreme Decree No. 1,043 which Contains New Tax Measures
Carey, July 2020

Resolution No. 61/202 of Chilean Tax Authority amends instructions on Certificate No. 66 on donations and expenses associated with the global outbreak of Covid-19 July 6, 2020 On June 17, the Internal Revenue Service issued the Resolution No. 61 through which it modified the Resolution No. 49, which creates the certificate that recipients must issue for the donations they receive in the context of the health crisis produced by Covid-19. According to Resolution No...

IRS Issues Guidance on COVID-19 Leave-Based Donation Programs
Hanson Bridgett LLP, July 2020

Key Points The cash value of employees’ donated leave time paid to a qualified charitable organization in 2020 under an employer-sponsored leave donation program is not taxable wages or compensation. Employers may take a tax deduction for such payments as a business expense or a charitable contribution...



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