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 ...
Panama’s current administration began its tax reforms with Law 49 of September 17, 2009 (Law 49/2009), that was followed by Law 69 of November 6, 2009 (Law 69/2009), Law 8 of March 15, 2010 (Law 8/2010), Law 33 of June 30, 2010 (Law 33/2010), and finally Law 31 of April 5, 2011 (Law 31 / 2011). All were implemented through formal laws and complemented with subsequent reforms in related executive decrees ...
The IRS has today released proposed amendments to the Code Section 892 regulations. Code Section 892 is the provision within the Internal Revenue Code that exempts foreign sovereigns from taxation in respect of investment income earned in the U.S. The primary amendments are described below. 1 ...
Order in Council no. 292/2011, published on 8 November, updated the list of countries, territories and regions with clearly more favourable privileged tax regimes ( known as ‘tax havens’) appearing in the earlier Order in Council no. 150/2004 of 13 February. It also excluded from the list two countries that are members of the European Union (EU): Cyprus and Luxembourg ...
The IRS has today released proposed amendments to the Code Section 892 regulations. Code Section 892 is the provision within the Internal Revenue Code that exempts foreign sovereigns from taxation in respect of investment income earned in the U.S. The primary amendments are described below. 1 ...
The Congressional Super Committee (the Joint Select Committee on Deficit Reduction) continues to meet in Washington, D.C., with the goal of reducing the country’s deficit through program cuts and revenue increases. There have been several unsubstantiated rumors regarding proposed changes to the estate and gift tax laws. One online rumor sparked particular interest even though no source was mentioned ...
Taxpayers subject to Tennessee ad valorem taxation should take note of the recent Initial Decision and Order by the Tennessee Board of Equalization in In re: Signal Mountain Cement Company (Hamilton County, Tax Years 2008-2011). The Administrative Law Judge (ALJ) rejected both the “value in use” methodology as well as the use of federal capitalization principles in valuing tangible personal property ...
1.- Tax treatment of different acquisitions: What are the differences in tax treatment between an acquisition of stock in a company and the acquisition of business assets and liabilities? The main difference from the acquirer’s perspective is that there is only a step-up in the tax basis on an asset purchase, while a stock acquisition as a general rule does not allow for a step-up on the basis of the target’s assets ...
As the end of the year approaches, it is a good time to consider actions that may lower your tax bill this year and possibly next year. High-income earners should consider that top income tax and capital gains tax rates are scheduled to increase after 2012, and Congress could raise taxes during 2012, which could make acceleration of dividends and capital gains to 2011 appealing ...
Following is a list of year-end administrative issues for Texas limited partnerships and limited liability companies (“LP/LLC”): Ensure that the LP/LLC’s activities, transactions, capital infusions (capital contributions or loan proceeds), and distributions are accurately reflected in the entity’s records; Avoid causing the LP/LLC to make any distributions not in compliance with the terms of its LP/LLC agreement or applicable law; for example, an LP/LLC should not make disproportiona
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The Minister of Finance has issued Regulation No. 130/PMK.011/2011 of 2011 on Income Tax Exemptions and Tax Reductions for Business Entities (“MOF 130/2011”) which constitutes an implementing regulation for Article 30 of Government Regulation No. 94 of 2010 on Taxable Income Calculations and Income Tax Payments for a Fiscal Year. This regulation has been in force since 15 August 2011 ...
On January 9, 2012, the IRS issued a news release announcing that the IRS is opening a third Offshore Voluntary Disclosure Program for taxpayers who come forward (including taxpayers who have come forward since the 2011 disclosure program closed last September) to report previously undisclosed foreign accounts and assets ...
Pursuant to the 2011 General Rules on Foreign Trade, since January 2, 2012, holders of trademarks that have been registered with the Mexican Industrial Property Institute (“IMPI”) may request the listing of their trademarks at the Mexican Customs Office (“AGA”), through a database developed by AGA ...
TAX REFORM The purpose of the current Angolan tax reform is to diversify sources of tax revenue (which up to now has been excessively dependent on oil), to modernise the Angolan tax system with a view to promoting greater tax justice and equity and also to increase the effectiveness and efficiency of the machinery of tax administration ...
Most of our clients are aware that Congress dramatically increased the individual gift tax exemption from $1,000,000 to $5,120,000 in 2012, and that the exemption is scheduled to revert to $1,000,000 on January 1, 2013 unless Congress takes some action. If this reduction in the gift tax exemption occurs, clients may lose an opportunity to remove a substantial amount of assets from their estates, and, with it, the opportunity to reduce estate taxes payable by their children ...
Not long ago, returns on traditional investment products, for example term deposits, were quite low and did not generate a great deal of interest among those who could spare and would like to invest money with the prospect of some return. Alternatives nearly always carry a higher risk and the various solutions, such as mutual funds, were not well known and poorly understood ...
Europe’s Finance ministers worked through the night of 20 to 21 February to hammer out the terms of the second Greek bail-out to the tune of EUR 130 bn. While the markets have responded coolly to the deal, ministers remain optimistic that enough has been done to stem the contagion to the rest of the Eurozone. Many experts remain skeptical as to whether the bail-out will be enough to save Greece from ultimately defaulting ...
On 26 January 2012 and 2 February 2012, the Council of Ministers approved two Agreements with the State of Qatar and the Special Administrative Region of the People’s Republic of China and also two international Conventions to Avoid Double Taxation and Prevent Tax Evasion in the area of Income Tax with Japan and the Republic of Colombia. It should be noted that international double taxation is an obstacle to commercial relations and the free movement of goods, services, people and capital ...
Over the last few years as tax revenues have decreased and budgets have tightened, states across the country have aggressively pursued out-of-state retailers that may owe sales or use tax. From ticket sellers like StubHub, online retailers like Amazon, and mail-order companies like Scholastic Books, states are asserting that a wide variety of businesses once thought to be exempt have the substantial nexus necessary to require that they collect sales and use tax from their customers ...
On 2 March, 25 of the 27 EU members committed to the new "Fiscal Compact" concept, signed the Treaty on Stability, Coordination and Governance in the Economic and Monetary Union. The Treaty, which is technically an intergovernmental treaty and not an EU instrument (due to the UK and the Czech Republic not wishing to sign up to it), was introduced in December 2011 by Germany and France ...
The latest additions to the Greek debt saga and the Eurozone crisis are the Credit Default Swap holders and the ISDA. But who are they and what is their role? What is a Credit Default Swap (CDS)? A CDS is most simply described as a type of insurance against the risk of a default on a debt issued by a third party (the reference obligor) ...
Contents * Recourses Seeking Rectification Under the New Business Corporations Act * You Do Business in a Province Other than Quebec: Are You Required to Register Yourself? * Resale Prices and Authorized Distributors: a Synopsis RECOURSES SEEKING RECTIFICATION UNDER THE NEW BUSINESS CORPORATIONS ACT Julie Cousineau jcousineau@lavery ...
