On 29 May 2017, Judge Fabricius delivered judgment in the Gauteng High Court in the case of Pienaar Brothers (Pty) Ltd vs Commissioner for the South African Revenue Service and the Minister of Finance, in a case dealing with the Taxation Laws Amendment Act, 2007 (the “Amending Act”) which inserted section 44(9A) into the Income Tax Act, 1962 (the “Act”) ...
Background On 10 September 2021, the Hong Kong Monetary Authority (HKMA) and People’s Bank of China (PBoC)released their respective implementation rules in connection with the cross-boundary Wealth Management Connect (WMC) pilot scheme in the Guangdong-Hong Kong-Macao Greater Bay Area (GBA) ...
The IVAucher programme was set up to stimulate private consumption in the sectors worst affected by the economic impact of the COVID-19 pandemic (catering, accommodation and culture). With regard to these sectors, “catering” is used in the broad sense to cover restaurants, cafés, bars and catering companies providing food and beverage services, and “accommodation” refers to hotels and other short-stay accommodation for holidays and business travel ...
The Internal Revenue Service (IRS) continues to generously interpret theFamilies First Coronavirus Response Act(FFCRA), deploying the “qualified leave tax credit” to maximize the benefit for employers and provide speedy aid, while adding new conditions to the “qualified family leave” mandate ...
This summer, the IRS significantly increased its efforts to police the taxation of Bitcoin, Ethereum, and other similar cryptocurrencies. On July 26, 2019, the IRS announced that it had begun sending letters to taxpayers who potentially failed to pay cryptocurrency taxes associated with digital currency transactions or failed to properly report those transactions. By the end of August, the IRS anticipates that it will have sent over 10,000 letters to taxpayers ...
On March 17, Treasury Secretary Steve Mnuchin announced a new tax plan to stimulate the economy during the COVID-19 crisis. Under the new plan, individuals and corporations can defer $1 million, and $10 million, respectively, in tax payments for 90 days. Importantly, individual and corporate taxpayers can take advantage of the new plan without incurring any interest or penalties ...
Download a free copy of the Philippine section of The International Comparative Legal Guide to: Telecoms, Media and Internet Laws and Regulations 2015, which was contributed by SyCipLaw partner Rose Marie M. King-Dominguez and senior associate Ruben P. Acebedo II ...
Having gone through a number of substitutions and amendments, the debt reduction rules contained in section 19 of the South African Income Tax Act, 1962 (the “Act”) and paragraph 12A of the Eighth Schedule to the Act now provide for the implications arising for a debtor where a debt owed to a creditor is waived, cancelled or capitalised by way of the issue of shares etc ...
On March 17, 2021, the IRS published IR-2021-59, postponing the deadline for filing individual income tax returns and payment of individual income taxes from April 15, 2021, to May 17, 2021. On March 29, 2021, the IRS issued Notice 2021-21, further clarifying the postponement of Federal income tax reporting and payment deadlines ...
In terms of the South African Income Tax Act, 1962 (the “Act”), distributions received by or accrued to a shareholder of a company may constitute either a dividend or a return of capital – each of which would give rise to different tax implications for the shareholder or company concerned ...
Corruption is a scourge which transcends frontiers. In response to this situation, Canada has chosen to pass the Corruption of Foreign Public Officials Act (hereinafter referred to as the "CFPOA") in 1998, then reinforced the regime thereof more recently. The difficulty with this Act lies in the fact that the offences must have been committed abroad. International cooperation thus remains essential to its application. The difficulties related to the transnational nature of corruption are real ...
IN THIS ARTICLE, ABHILAASH SUBRAMANIAM DISCUSSES THE POTENTIAL IMPLICATIONS OF THE MOVE FROM GST TO SST. Introduction The much anticipated Sales Tax Act 2018 and the Service Tax Act 2018(commonly referred to as “SST”) was rolled out on 1 September 2018, together with their respective subsidiary legislations, to replace the previous Goods and Services Tax Act 2014 (“GST”) ...
The implications of FATCA in South Africa (written exclusively for Bloomberg BNA, Tax Planning International, European Tax Service, volume 16, number 7, July 2014) Written by Hanneke Farrand, director, and Caroline Rogers, senior associate, both in the tax department at ENSafrica. I. Background The Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the USto target non-compliance by US taxpayers using foreign accounts ...
The President of the United States of America, George W. Bush, announced today the Implementation of the Dominican Republic-Central America-United States Free Trade Agreement, DR-CAFTA, with respect to the Dominican Republic. See press release from The White House http://www.whitehouse.gov/news/releases/2007/03/20070301.html#).The implementation of this free trade treaty opens a new era of commercial opportunities between the member countries to the DR-CAFTA ...
Defining your strategy and analysing the market are crucial when making the decision to invest in China, but the tax efficiency of the business has its own specific issues and investors should not neglect them either. The Chinese tax system has particular characteristics that you must get to know before investing. In this informative note, we will address some basic aspects of value added tax and the invoicing system ...
Changes to North American Free Trade Agreement (NAFTA) have been anticipated since the moment of President Trump’s election. When U.S. Trade Representative Robert Lighthizer notified Congress of the Administration’s intent to renegotiate NAFTA, he triggered the 90-day consultation period before formal negotiations can begin ...
The most general reason for setting up a trust is to ensure the effective and professional legal protection of assets. Contrary to a private foundation, there is no legal requirement to set forth a specific objective for the trust ...
The two financial centres have long been considered twins, but where do the similarities end and the differences begin? Hong Kong, now entering its 15th week of protests, has been filled with increasingly incendiary rhetoric and escalating violence. This past weekend saw protesters lighting fires at an MTR station entrance, just outside the uber-luxe Bulgari boutique in Central ...
This Tax Alert summarizes a recent ruling of the Gujarat High Court[1] which discussed the issue that whether a taxpayer is entitled to refund of the IGST paid on import of capital goods under Export Promotion Capital Goods (‘EPCG’) Scheme for the interim period between 1 July 2017 i.e ...
These days the Ministry of Taxation is leading a crusade against Danish companies that have omitted to withhold tax at source in connection with the payment of dividend or interest to intermediary holding companies abroad. It is claimed that the companies are liable for the tax that has not been withheld ...
On March 28, 2024, the Department of Finance Canada announced a one-year extension to the 15% Mineral Exploration Tax Credit (?METC?) available to investors in flow-through shares. The extension means that the METC will be effective until March 31, 2025. This announcement came at a time when uncertainty loomed over the industry and some stakeholders feared that the government would not renew the METC. Over time, this tax credit has become a key component of flow-through share financings ...
The GDPR contains rules on when it is mandatory for controllers and processors to designate a data protection officer. The Article 29 Data Protection Working Party (WP29) issued guidelines on the data protection officers (DPOs) interpreting the respective provisions of the GDPR (Articles 37-39 and Recitals 77 and 97). The Data Protection Officer (DPO) The GDPR contains rules on when it is mandatory for controllers and processors to designate a data protection officer ...
Comment from Paula Swain, Partner National Head of Commercial Recoveries and Head of the Solent office for Shoosmiths, Paula is also a Director with the Solent LEP and was part of the Freeport taskforce which was successful in its bid ...
