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 ...
The Supreme Court ruled last week in Microsoft Corporation v. i4i Limited Partnership that “clear and convincing evidence” is still the standard of proof required to invalidate a patent. Section 282 of the Patent Act states that “a patent shall be presumed valid” and that “[t]he burden of establishing invalidity of a patent or any claim thereof shall rest on the party asserting such invalidity ...
What are the current gift tax rules and what will happen in 2013? Prior to January 1, 2011, the gift tax exemption was $1,000,000, meaning you could give away $1,000,000 over the span of your life without having to pay a gift tax. For 2011 and 2012, you can give away up to $5,000,000 without a gift tax. That is five times the amount previously allowed. If the aggregate amount of your gifts exceeds $5,000,000, the gift tax rate during 2011 and 2012 is 35% (reduced from 45% in 2009) ...
The IRS has apparently increased its focus on unrelated business taxable income (“UBTI”) of tax-exempt organizations. At a conference last month, IRS officials indicated they are looking closely at UBTI in all contexts with respect to exempt organizations, including conducting a long-term study on college and university treatment of UBTI ...
With the U.S. economy not as robust as it once was, it seems that Americans are currently more interested in selling their Canadian assets, particularly recreational property, than buying Canadian assets. It is therefore useful to consider the issues that arise when a U.S. person sells Canadian real estate. The following points are relevant: The U.S ...
On May 4 2011 the Ministry of Finance of the Russian Federation published on its website the draft law on transfer pricing, which includes the amendments introduced after the first reading held o February 19, 2010 ...
The interaction between the Treaty and Uruguayan tax rules Permanent establishment (Pe)1 and Fixed base for business (Fbb)2 The concept of permanent establishment3 for corporate activity, and the concept of a fixed base for business4 for independent individual workers establish the mechanism for apportionment of tax-raising powers between both countries for income of a nature defined in those countries ...
The Social Network did not just tell the fascinating story of Facebook's rise to a social media power house. It showed how society is increasingly using social platforms as one of its primary channels for communication. Social media is broader than social networking sites such as Facebook or Linked-In ...
Imitation is the sincerest form of flattery — so they say. Boosters in Wellington, New Zealand, call themselves “Silicon Welly.” And Texas Gov. Rick Perry said somewhere in America “Silicon Valley will be replicated. I want it to be in Austin” — even though central Texas dubbed itself “Silicon Hills” long ago. There’s also the Silicon Forest, Prairies, Alleys and other Valleys. Not to mention the No. 1 Silicon Alley — in New York City ...
All businesses possess confidential information - trade secrets, customer lists, staff records - which could mean loss of business, reputational damage, or give competitors an advantage if leaked, whether deliberately or accidentally.Depending on the type of information disclosed and the type of organisation, there are potential consequences regarding public policy and data protection ...
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 ...
Contents* Major Relief for Non-Residents of Canada * A New act on Legal Publicity * Stock options Can Be advantageous, But Be Careful! * Adoption of IFRS and Recent GaaP Changes: The impact on Credit agreements MAJOR RELIEF FOR NON-RESIDENTS OF CANADAPhilippe Asselinpasselin@lavery ...
In the latest in a series of legal challenges around internet keywords and particularly the Google AdWords system, the special adviser to the Court of Justice of the European Union, Advocate General Jaaskinen, has issued his opinion ...
* The New Act Respecting the Legal Publicity of Enterprises and Trusts * New Filing Requirements for Partnerships * Requests for Production of Documents by the Tax Authorities * Your’re Fired!: The Impact on the Exercise of Stock Options THE NEW ACT RESPECTING THE LEGAL PUBLICITY OF ENTERPRISES AND TRUSTS André Paquette apaquette@lavery ...
These days many US businesses are looking north to Canada for new markets. This paper discusses when a US business needs to worry about the Canadian tax system. The short answer comes from some of the oldest provisions in the Income Tax Act. US businesses need to worry about Canadian tax when they have a physical presence in Canada. To read this paper, click here. For more information please contact Len Glass at [email protected] or 604.631.9140 ...
Recently, the Exempt Organizations Office (“EO”) of the IRS released a list of 2011 initiatives, including international activities and compliance. The following are just a few of the items on the IRS’s radar for the coming year. Employment Tax Examinations. In 2011, the EO plans to conduct full examinations of 500 exempt organizations to determine compliance with employment tax rules as part of a project reviewing employment tax practices of both taxable and tax-exempt organizations ...
Website accessibility is a requirement of the Equality Act 201. The first of a two-part article explaining Equality Act 2010 to websites. In our last article, Website accessibility: Industry standards and best practice, we considered how the Equality Act 2010 would be implemented, and considered what the new BSI Standard for website accessibility might look like ...
Concents : * Technology Licences in the Event of Bankruptcy * New Quebec Business Corporations Regime * The Shareholder Agreement: the "Specifications" of the Private Corporation Shareholder Technology Licences in the Event of Bankruptcy Sive Burns [email protected] The owner of a technology protected by an intellectual property right (copyright or patent) or protected by secret (trade secret) may grant a licence to a licensee ...
On February 8, 2011, the IRS announced a second voluntary disclosure program that will allow U.S. taxpayers to disclose offshore accounts that were previously kept secret from the IRS. U.S. citizens and resident foreign nationals are required to pay U.S. federal income tax on their worldwide income. The objective of this initiative is to bring taxpayers that have used undisclosed foreign accounts to avoid or evade taxes into compliance with United States tax laws ...
The Federal government’s legislation to control spam and other ills of the electronic age with the oh-so-catchy title of An Act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage reliance on electronic means of carrying out commercial activities, and to amend the Canadian Radio-television and Telecommunications Commission Act, the Competition Act, the Personal Information Protection and Electronic Documents Act and
The last minute compromise which averted the expiration of the Bush tax cuts included a two-year modification of the estate, gift, and generation-skipping taxes. For 2011 and 2012, every individual will have a $5 million gift tax exemption. For individuals dying in 2011 or 2012, the estate tax exemption is also $5 million, and the generation-skipping transfer (“GST”) tax exemption for transfers during life or at death is $5 million ...
1. How can the government’s attitude and approach to internet issues best be described? The attitude of the Belgian government can be described as positive and their approach is proactive. In 2003, the Belgian authorities announced the introduction of ‘egovernment’ ...
In the second of a two-part look at issues arising out of the tender process we consider what can happen when that process is poorly run. Part 1 of the series can be found at IT tendering: Leveraging the benefits. A typical tender process involves the customer analysing and documenting its requirements in a Request for Proposals (RFP) to which interested suppliers will prepare a response ...
