On December 9, 2022, the Office of Chief Counsel of the Internal Revenue Service (“IRS”) issued a General Legal Advice Memorandum (“Memorandum”) challenging the 1994 Tax Court decision inChilds v. Commissioner, 103 T.C. 634 (1994),aff’d without published opinion, 89 F.3d 856 (11thCir. 1996) (“Childs”) ...
In recognizing the serious humanitarian crisis and potential health ramifications to the population of the United States and the World, the IRS announced on Thursday, October 29, 2014, in a pair of Notices that the Ebola outbreak occurring in the Western Africa countries of Guinea, Liberia, and Sierra Leone is a qualified disaster for certain purposes of the Internal Revenue Code ...
The IRS plans to begin recurring market segment examination of tax-exempt bonds, including the hospital market, according to statements made by Bob Griffo, Supervisory Tax Law Specialist with the Internal Revenue Service (IRS), at a recent National Association of Bond Lawyers conference. For the first year of the program, the IRS plans to examine between 20 to 40 tax-exempt hospitals ...
An updated version of this article is available ? On March 20, 2020, the Internal Revenue Service (IRS) and the U.S. Department of Labor (DOL) jointly issued guidance regarding the tax credits available to certain small employers who are required to provide new types of paid leave to employees under the Families First Coronavirus Response Act (Act), enacted on March 18, 2020 ...
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”) ...
On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 to provide guidance related to business interest expense limitations and elections available for certain real property trade and farming businesses under Section 163(j)(7) of the Internal Revenue Code (the “Code”) ...
Asters Law Associates Oles Kvyat and Oleksandr Mozheiko talk today about the terms and procedures of the Initial Public Offering on the Ukrainian Stock Exchange The Ukrainian market grows in line with global markets. When global markets decline, the Ukrainian equity market suffers correction as well. The recent financial turmoil experienced by the world in 2009 - 2010 adversely affected the Ukrainian equity market ...
SerbiaIncreased number of applications for industrial property protection It seems that the promotional efforts of the Intellectual Property Office of Serbia have been effective. According to statistics from the IP Office for 2013, the number of trademark applications increased by 40%, the number of patent applications increased by 5% and industrial design applications increased by 42% compared to last year ...
Investors in Scottish commercial property have been warned that the sector may see a zero per cent rate of growth in 2008 as supply continues to outstrip demand.In comparison to the situation just 12 months ago, where there were ten buyers for every commercial property put on the market, now ten sellers exist for every purchaser, new research from industry consultants Drivers Jonas has revealed ...
In our geography in constant transition, resources must be shielded, which is why we must revisit as investors the macro trends as economists call it, prudence in investment matters is imposed without restraining dynamism, only taking it in a gradual and diversified way. Investing in companies or funds with a green seal is one of the strategies that have been outlined for this new year 2020 ...
Colombia updated its free trade zones regime to increase the competitivity of this investment opportunity. Among others, it now allows three new activities for free trade zones, introduces the creation of a concertation committee to discuss key topics between the Government and the private sector, and it simplified procedures to declare a free trade zone. Decree 278 of 2021 was introduced as a tool towards innovation in the free trade zone regime ...
This quarterly newsletter summarizes some of the recent administrative actions that will go into effect this year and which will impact funds and their advisers, beginning with the EDGAR requirements that mutual funds and separate account issuers designate new codes for each series and class when making their EDGAR filings ...
General socio-economic overview The Republic of Mozambique is situated on the east coast of southern Africa. It is bordered to the north by the Republic of Tanzania, to the northeast by Malawi and Zambia, to the west by Zimbabwe, to the south by Swaziland and to the south and west by South Africa. It is therefore very strategically located, providing a gateway to six other countries ...
PLMJ has launched the new version of its Portugal Investment Guide, which reflects PLMJ’s experience in handling innumerable investment projects in Portugal in a range of sectors, throughout its 45-year history.This Investment Guide proves that Portugal has increasingly competitive conditions – in terms of technology, workforce, infrastructure, logistics, geography, law and tax – to continue to attract large-scale investment projects ...
The benefits of Guernsey as a fund domicile. Guernsey is one of the world’s largest offshore finance centres, with a thriving funds industry. Over 1,400 investment funds and sub-funds are currently administered in the island. The value of funds under management and administration in Guernsey as at the end of June 2021 is US$533 billion (up 24.4% in 12 months), based on the most recent available data published in The 27th annual Monterey Insight Guernsey Fund Report ...
This Order . which came into effect on 1 December 2005, facilitates the expansion of the electronic filing system in the Companies Registration Office. Companies may now appoint Electronic Filing Agents to sign and file documents with the CRO in electronic form. The Minister of State at the Department of Enterprise, Trade and Employment, Mr Michael Ahern, stated, “The introduction of a statutory Electronic Filing Agent will greatly simplify the process for companies and their agents ...
Graham Thompson Partner Ryan Pinder authors a comprehensive review of Investment Funds in The Bahamas. Arranged in a Q&A stlyed format to address some of the queries and issues that frequently come up. The review is structured around the components: Fund Formation Fund Investment Regulatory Environment Fund Finance Tax Environment A ...
PrefaceThis guide is written as an introduction to Ukrainian legal system from the viewpoint of foreign investors, in particular Chinese ones, and will help you in deciding whether to do a deal in Ukraine and what strategy should be chosen when investing in this country. The digest of key legal issues may be found helpful both at the stage of initial investment research and in the course of a particular investment project ...
The benefits of Guernsey as a fund domicile Guernsey is one of the world's largest offshore finance centres with a thriving funds industry. Guernsey’s experience in private equity dates back to the early 1980s when the private equity industry was in its infancy, since then Guernsey has grown to become a leading jurisdiction for the formation and administration of private equity funds ...
I. INVESTING EM ANGOLA TODAY: INTERNATIONAL TAX MANAGEMENT At times the interest Portuguese companies have in the Angolan market has lived alongside the fear that there are factors that discourage investment in the country. In contact with businesspeople linked to a wide variety of sectors, we have been able to witness on the one hand, demonstrations of high levels of motivation and, on the other hand, signs of scepticism as to what the virtues of investing in Angola may be ...
Introduction of Section 7C to The Income Tax Act and its Effect on Estate Planning Section 25B(1) of the Income Tax Act provides that any amount received by or accrued to or in favour of any person during any year of assessment in his/her capacity as a trustee of a trust, to the extent to which such amount has been received for the immediate or future benefit any ascertained beneficiary who has a vested interest to that amount during that year, this shall be deemed to be an amount that
