In a major win for sellers of services and intangibles, the Ohio Supreme Court ruled on Sept. 29, 2020, that a taxpayer is entitled to Ohio Commercial Activity Tax (CAT) refunds stemming from its sale of contracts to an out-of-state buyer ...
A recent Ministerial Order1 from the Minister of National Revenue has formally extended certain deadlines under the Income Tax Act (“ITA”) and the Excise Tax Act (“ETA”). The Order is retroactive to March 13, 2020. The extension is 6 months or until December 31, 2020, whichever is earlier. This Ministerial Order will have various implications for taxpayers and registrants, in particular in terms of limitation periods ...
How is taxable income determined in your state? To what extent is the state income tax base aligned with the federal income tax base? Alabama levies a corporate income tax on business entities classified as taxable or “C” corporations that have nexus with the state and are not classified as “financial institutions” or insurance companies subject to a separate premium license tax; and it levies a FIET on business entities classified as financial institutions havin
SyCipLaw TIP 1: Based on reports, the BIR is considering applying a minimum threshold on who will be required to submit BIR Form No. 1709. The threshold may be based on the assets or revenue of the entity or the size of the transaction, or both. However, until the BIR issues the relevant circular, a taxpayer entering into transactions with related parties must ensure that it complies with the requirements under RR No ...
We would like to take this opportunity to remind our readers that the immovable property tax (“TOIP“) and Unused Land Tax deadline for 2020 is next Wednesday the 30th of September 2020. The 2020 TOIP and Unused Land Tax payment can be made at any tax branch or any branch of Canadia, Acleda, Vattanac or Cambodia Public Bank. Those already registered for TOIP and Unused Land Tax need to provide their 2019 tax payment receipt or Property Tax Registration Identification Card ...
In recent months, a number of changes to the Russian tax legislation, implying long-term effects for both Russian taxpayers and foreign investors, are taking place. Amendments to the Double Tax Treaties ('DTTs') are among of the most important ones. Below, we provide our consolidated analysis of the forthcoming changes and recommendations on steps to prepare for them ...
The Tax Court of Canada (the “Court”) recently upheld the deductibility of carrying charges incurred in connection with an issuance of shares. In so doing, the court upheld the tax benefits arising from a common financing practice. In addition, the Court reiterated the principle in tax matters according to which, save in exceptional cases, the legal relationships established by one or more taxpayers must be respected ...
Complementary Law No. 175/2020, enacted in September 23, 2020, determined that the Service Tax (ISS) must be shared between the municipalities where the service providers and the clients are located. Complementary Law No. 175/2020, enacted in September 23, 2020, determined that the Service Tax (ISS) must be shared between the municipalities where the service providers and the clients are located ...
Cybersecurity will generally be a significant issue for businesses in the years to come. With teleworking, cloud computing and the advent of artificial intelligence, large amounts of data are likely to fall prey to hackers attracted by the personal information or trade secrets contained therein. From a legal standpoint, businesses have a duty to take reasonable steps to protect the personal information they hold ...
On Saturday, September 12, 2020, the Internal Revenue Service (“IRS”) updated a marijuana industry frequently asked questions (“FAQ”) page that provides relief to state-legal cannabis businesses. The FAQ announces that state-legal cannabis businesses can reduce their gross receipts by using an alternative accounting method under Section 471 of the Internal Revenue Code (the “Code”) ...
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 ...
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 ...
COVID-19 has sent many employers into a workforce management tailspin. Laws, regulations, and recommendations change daily, and as the pandemic continues to affect the workplace, the risk of legal complacency increases. The list below identifies the top 10 mistakes for employers to avoid during the COVID-19 pandemic. Mistake 1: Failing To Prepare and Update a COVID-19 Response Plan ...
To create the most favorable environment for the intensive development of the IT industry and pooling resources for the new projects, the Russian Government has adopted a Law introducing a number of changes and tax incentives for the IT and Technology Companies. It will be effective starting from January 1st, 2021. Below, we provide our consolidated analysis of the new rules and recommendations on steps to be taken to prepare for the forthcoming changes ...
On 12 September 2020, the UAE Ministry of Health and Prevention (MoHAP) reported 1007 new COVID-19 cases in the UAE. With the number of cases rising both within the UAE and in most other countries, the UAE government has reiterated the importance of adhering to preventive guidelines and has further placed safeguards, particularly in Abu Dhabi, to ensure that those traveling to the UAE are confined to prevent the transmission of the virus ...
Law is an ever-evolving social construct and remains effective only insofar as it can be updated in a timely manner to keep up with real-life developments. The relevance of laws and their subject matter is always dictated by present-day realities and circumstances ...
INTRODUCTION Information Communication Technology (ICT) has, without a doubt, greatly impacted virtually every industry, and the communications industry is no exception. Services such as bulk short message service (SMS), online games, data services, telemarketing, text messages and media messages, all of which are often referred to as Value Added Services (“VAS”), now constitute a part of our daily lives ...
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 ...
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 ...
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 ...
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 ...
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 ...
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 ...
