Paul Carney and Craig Thomas explore the impact of the Chancellor's 2023 Spring Budget on the taxation of pensions in the UK. The Chancellor’s budget statement on 15 March caused many to be surprised and some to be perplexed ...
The World Pension Summit (Africa), first of its kind in Africa, was hosted in Abuja on 7 and 8 July 2014. The summit focused on African developments in the pension industry and coincided with the 10th anniversary of the pension reform in Nigeria that led to the enactment of the Pension Reform Act No 2 of 2004 (“the 2004 Act”) ...
Is the current international tax focus on base erosion and profit shifting (“BEPS”) relevant for tax-exempt pension funds? In particular, should the trustees and/or administrators of pension funds take note of the finalisation by the Organisation for Economic Co-operation and Development (“OECD”) of the 15 point action plan to address BEPS? Both of these questions should be answered “yes” by South African pension funds that invest outside of the country ...
In the case of Claremont Library Development Company (Pty) Ltd v The Commissioner for the South African Revenue Service, the Tax Court recently considered the question of whether crediting a loan account constitutes “payment” of full consideration for purposes of the Value-Added Tax Act, No 89 of 1991 (the “VAT Act”) ...
The internationalization of trade has led to an increase in payments made by Canadian companies to non-residents of Canada, which are most of the time subject to Canadian withholding taxes. Canadian payers must ensure that they withhold the correct percentage of Canadian tax on such payments, as they are liable to the tax authorities for any failures on their part in this regard ...
Possession, as they say, is nine tenths of the law. Generally in commercial litigation where, for example, a claim for an outstanding amount is brought against a party, such party is not required to make payment to the claimant until a court has adjudicated on the matter. However, when it comes to matters of tax, the Tax Administration Act, No ...
Gone are the days when marketing campaigns are relegated to just hard copy printed materials. They are more often than not found, promoted and run online, and increasingly through social media which offers a speedy and an efficient method of an organisation speaking to its audience. It also offers the audience the opportunity to like, share and comment on the campaign, providing a unique and ‘in the moment’ conversation between a business and its customers ...
On April 8, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-23, which allows eligible partnerships to file amended partnership returns for taxable years beginning in 2018 and 2019 in order to take advantage of the various tax incentives provided under the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) ...
New rules found in Internal Revenue Code sections 6221 through 6241, as amended by the Bipartisan Budget Act of 2015, govern IRS tax audits of partnerships, limited liability companies, and other entities and arrangements classified as partnerships for U.S. federal income tax purposes. The changes made by these rules will significantly impact partners in partnerships and careful attention should be paid to these rules by all partners in partnerships ...
If a Code Section 501(c)(3) organization (501(c)(3)) or State or local government (collectively Exempt Entity) hospital or other facility financed with tax-exempt bonds has “too much” private business use of such facility, the bonds will lose their exempt status. Various arrangements, including partnerships or management agreements with non-exempt persons can constitute private business use ...
Overview A VASP will need: a licence (a "Part III VASP Licence"); and to be regulated by the Guernsey Financial Services Commission (the "Commission"). A Part III VASP Licence is required unless an exemption is available under the LCF Law or the "Notice with respect to the disapplication of the requirement to hold a licence under section 40 of the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022" (the "LCF Notice") ...
In November, California voters narrowly passed Proposition 19, which makes significant changes to existing real property tax reassessment rules. Effective after Feb. 15, 2021, Proposition 19 significantly restricts property owners' ability to preserve the current assessed value of California real property transferred between parents and children. Effective Apr ...
Troy Schooneman, partner and head of Kudun and Partners’ International Practice was invited to be a panelist at the World Services Group(WSG)’s Asia Pacific Region Discussion on Offshore Law Regime, a collaborative online seminar organized by the World Services Group (WSG) together with Kudun and Partners, an award-winning independent law firm in Thailand; Carey Olsen, a leading offshore law firm advising on Bermuda, British Virgin Islands, Cayman Islands, Guernsey and Jersey law, an
Law 37 of June 5, 2018, adds line 9 to article 709 of the Fiscal Code, which is related to the annual income tax deductions to which natural persons are entitled, regarding school expenses incurred by the taxpayer with respect to their dependents. Additionally, Executive Decree 368 of December 26, 2018 and Resolution No. 201-1635 of May 13, 2019, establish the regulations applicable to the deduction of said expenses ...
As Panama became part of a number of industrial property related treaties, our internal laws have become more territorial; the use of a trademark is territorial again and registration becomes imperative for protection. In Panama, as happens in most of the countries around the world, the right to register a trademark is acquired by its first use in commerce ...
The Republic of Panama, using Law No. 35 of May 10, 1996 as a basis, continues making its best efforts to provide the highest possible protection to Intellectual Property, both in the territory of the Republic of Panama as well as also cooperating with the owners of intellectual property rights ...
To protect and stimulate creators to increase innovation and encourage entrepreneurship, Norwegian authorities are changing the law. In 2018 we received several proposals towards strengthening the rights of those who create new ideas or build their business on intellectual property. Looking back at 2018, we see a year in which the Norwegian intellectual property (IP) legislation has been in movement. Technology is developing fast, and so must the law protecting technology ...
Software is becoming the main part of an increasingly amount of products set on the market; a trend which will become more and more evident in the years to come. This fact challenges the legal landscape and interpretation of product liability laws, and contract makers must pay attention to potential new risks imposed on the parties. If a product causes damages to a third party, complex questions may arise with respect to liability and the chain of causation ...
PSD2 came into effect in the European Union on January 13, 2018. PSD2 is important as it aims to further harmonise the EU payments market and break the banks' de facto monopoly on the provision of payment services and the use of their customer data. Below is a review of developments to date as they relate to transposing PSD2 into Norwegian law, including an update on the most recent developments ...
Despite a positive and active start in H12018 with high M&A activity in the Norwegian market, the total number of completed deals in Norway in 2018 will be significantly lower than in 2017. YTD it has been registered 248 completed deals in Norway compared to 346 in 2017 (full year) ...
Entity classification refers to a set of rules used in the U.S. tax system to classify entities for the purposes of the Internal Revenue Code. Once classified, the entity will either be subject to the Code rules for corporations or the Code rules for partnerships. The Canadian tax system, on the other hand, does not have entity classification rules. Instead, the Canadian tax system simply categorizes entities for tax purposes based on their classification under commercial law ...
The Government of Indonesia moves forward the development of Indonesia’s new capital city, namely Ibu Kota Nusantara (“IKN”) by issuing several underlying regulations to date in effort to encourage the participation of private sector in accelerating the infrastructure development of the IKN. One of them being the groundworks to implement the public-private partnerships in such development ...
On November 23, 2023, the State Council published theOfficial Reply of the State Council on the Work Plan for Supporting Beijing in Promoting the Construction of a Comprehensive Demonstration Zone for Further Opening up the National Service Sector(the "Reply") ...
States’ responses to the global pandemic may, however well-intended, harm the interests of inward investors. Under international public law, those investors have rights and so a spate of investor-State arbitral claims may well be a legacy of the pandemic. Across the world, governments have responded to Covid-19 by introducing emergency measures, which have inhibited social interaction and hampered economic activity ...
It currently appears that Texas may join a growing number of states that have passed laws aimed at increasing tax collection from online retail transactions. On Wednesday, April 27, 2011, the Texas House passed H.B. 2403, which provides that out-of-state retailers that have relationships with certain Texas “affiliated” entities will be deemed to be doing business in Texas for purposes of the sales and use tax. H.B. 2403 will now be sent to the Texas Senate for consideration ...
