By: Ruben Gotlieb, Esq. As many of you know by now, Donald Trump has won a second term as president. Additionally, Republicans in the U.S. Senate will have a small majority in Congress. It is still uncertain who will hold a majority in the House of Representatives. What does this mean for tax legislation set to expire, or “sunset,” at the end of 2025? To pass a permanent tax law, a majority of at least 60 senators is needed. Without this, the law can only last for 10 years ...
The new Network and Information Systems Directive (NIS2) came into effect on 18 October 2024 and with it comes an overhaul of the way in which cybersecurity risk management is regulated in Europe. The major changes brought about by NIS2 include stricter security measures, new incident reporting obligations and will substantially expand enforcement powers for regulators ...
The UK’s Chancellor, Rachel Reeves, is set to deliver her first Budget on 30 October and it is anticipated to bring significant changes to the tax landscape. With the Government having identified a funding shortfall of £22 billion, it seems almost inevitable that tax rises are on the way, with capital gains tax (CGT) squarely in the Chancellor’s sights. We’ve outlined some potential changes and key considerations that may be relevant before, and after, Budget Day ...
We are pleased to present the very first edition of our Trade and Taxation Newsletter. Each month, we will share important updates, key developments, and practical insights on trade and taxation, all tailored to help you stay ahead in an ever-changing regulatory environment ...
SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for August which covers the following tax issues: 1. What are the options of the taxpayer in case of overpayment of creditable withholding tax ("CWT")? Are these options irrevocable? 2. Does the irrevocability rule under Section 76 of the Tax Code apply to a corporation even if it is already in the process of dissolution? 3 ...
Previously ALRUD reported that an increase of the “exit tax” up to 40% of the valuation was being discussed by the Russian Government. The new information provided by ALRUD’s sources suggests that the “exit tax” will be increased ****up to 35%**** total, with ****three separate payments within 2 years**** from closing of a transaction. Please note, however, that no official statements have been made by the authorities ...
Establishment of Bermuda’s Corporate Income Tax Agency Following the enactment of Bermuda’s Corporate Income Tax Act (the “CIT Act”) in December 2023, in July 2024, the Government of Bermuda passed the Corporate Income Tax Agency Act (the “Agency Act”) which, among other things, (i) establishes the Bermuda Corporate Income Tax Agency (the “Agency”); (ii) sets out the functions and powers of the Agency with respect to administration of the CIT Ac
Administration of Bermuda's Corporate Income Tax Act 2024 In August 2024, Bermuda’s Ministry of Finance published a public consultation paper setting out certain proposed compliance obligations for Bermuda corporate taxpayers including certain anticipated procedural requirements with respect to registration, tax return filings, and payment of taxes ...
Administration of Bermuda's Corporate Income Tax In August 2024, Bermuda’s Ministry of Finance published a public consultation paper setting out certain proposed compliance obligations for Bermuda corporate taxpayers including certain anticipated procedural requirements with respect to registration, tax return filings, and payment of taxes ...
Taxation of Guernsey Funds Guernsey does not levy any form of capital gains tax, inheritance tax or value added tax. No stamp or document duty, or transfer tax, is payable in respect of companies, unit trusts or limited partnerships that are collective investment schemes. The income tax position for fund vehicles is detailed below. Companies A company incorporated in Guernsey or centrally managed and controlled in Guernsey is treated as tax resident in Guernsey in any year of charge ...
SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for July which covers the following tax issues: 1. Is a taxpayer always required to make the "payment under protest" under Section 252 of the Local Government Code of 1991, as amended, to assail real property taxes? 2. May services rendered to foreign entities outsourcing manpower recruitment in the Philippines qualify for a zero percent rate of value-added tax ("VAT")? 3 ...
On 9 September 2024, Mario Draghi, former Italian Prime Minister and European Central Bank President, presented his highly anticipated report on «The Future of European Competitiveness» to European Commission President Ursula von der Leyen [1][2]. This comprehensive report analyzes the challenges faced by European industries and companies in the Single Market and proposes strategies to enhance the EU’s competitiveness [2] ...
SyCipLaw's Tax Department has prepared a double edition of its Tax Issues and Practical Solutions (T.I.P.S.) for May-June. The May-June 2024 issue covers the following tax issues: 1. Under the current VAT regulations, is input tax required to be directly attributable (or a factor in the production chain) to zero-rated sales, i.e., to come from purchases of goods and services that form part of the finished product of the zero-rated taxpayer in order to be creditable or refundable? 2 ...
SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for April. The April 2024 issue covers the following tax issues: 1. In assessing deficiency withholding tax on compensation of employees who were not individually identified, is it proper for the Commissioner of Internal Revenue ("CIR") to use the top withholding tax rate of 32%? 2. Which court has exclusive and original jurisdiction over criminal offenses involving tax claims amounting to PhP 1,000,000 ...
On July 22, 2024, the European Commission approved revised Interpretative Guidelines (the “Guidelines”) on Regulation (EC) No 261/2004 (“Regulation 261/2004”), which address air passenger rights concerning compensation and assistance for denied boarding, cancellations, and delays and on Regulation (EC) No 2027/97 on air carrier liability in case of accidents ...
Simplified Stock Companies (SAS) have been implemented in El Salvador as a corporate solution aimed at micro-entrepreneurs and informal sector merchants who, due to entry barriers established in various regulatory bodies, were discouraged from forming a traditional corporate vehicle (e.g., Corporation, Limited Partnership, Limited Liability Company, among others) to conduct their business. In pursuit of the objective mentioned above, the reforms to the Commercial Code (C. Com ...
Tax opportunities under the Indian Act Although it is not often well-understood in business and tax circles, the Indian Act (the ?Act?), coupled with federal and provincial tax laws, provides several tax planning opportunities for Indigenous taxpayers. These laws provide various tax exemptions for people who qualify as ?Indians? under the Act, as well as for ?bands? and other ?councils ...
Shipping and Bermuda’s Corporate Income Tax Act The initial taxing determination You have determined that you have a shipping entity within a “Bermuda Constituent Entity Group”, which itself is within an “In Scope MNE Group” for the purposes of the Tax Act. Furthermore, you have already made various adjustments to the taxable income in accordance with Part 6 of the Tax Act ...
A recent appeal case upheld a breach of contract claim over a lifetime rail travel benefit delivered by a third-party provider. We examine the case and how employers can avoid such disputes through clear terms and conditions for employee benefit schemes ...
Transfer Pricing rules are fundamentally based on the Arm’s Length Principle, articulated in art. 9 of the OECD Model Tax Convention. This principle is pivotal for bilateral and multilateral tax treaties to avoid double taxation, reiterated in point 1.6 of the OECD’s “Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ...
The Supreme Court has overturned the Chevron Doctrine–a four decade-old ruling that enabled Federal agencies, including the Internal Revenue Service (“IRS”), to interpret ambiguous laws passed by Congress, and to have such interpretations enjoy a significant degree of deference ...
The Automated Vehicles Act (the Act) outlines the safety requirements that manufacturers and operators of automated vehicles will need to meet in order to deploy their goods and services on UK roads. In this article Ben Gardner outlines the key safety areas that will need to be considered ...
On 12 June 2024, the Office of Rail and Road (ORR) published its final report, ‘Railway Station Catering Market Study’. It evaluates the effectiveness of competition in station catering and whether the market is delivering value for money for passengers and taxpayers. The ORR has identified barriers to competition, such as limited space and protected leases ...
The Automated Vehicles Act (the Act) outlines how liability will be allocated when an automated vehicle commits a driving offence or is involved in an accident, together with certain information disclosure requirements to support regulatory investigations. In this article Ben Gardner outlines the key issues surrounding liability that will need to be considered ...
The Automated Vehicles Act (the Act) creates a licensing and permitting scheme for operators that intend to use automated vehicles to offer transportation services for passengers and goods. In this article Ben Gardner outlines what potential operators need to consider ...
