1. Interest on Equity and Dividends: the Brazilian Perspective Brazilian companies have two main instruments for remunerating shareholders for the capital invested in companies: dividends and interest on net equity (“Juros sobre o capital própio”, referred to as “IoNE” in this article). Both instruments can be used at the same time, but their tax treatment will depend on the particular characteristics of each case ...
The Philippine Securities and Exchange Commission (SEC) issued Memorandum Circular No. 1, s. 2013 dated 7 January 2013, requiring the incorporation of the tax identification number (TIN) of foreign investors in all forms papers and documents filed with the SEC ...
Acquiring investment property This alert is intended to highlight certain VAT issues relating to the purchase and management of property which is subject to a lease(s). In general VAT should not be chargeable on the sale of such property. Depending on the circumstances this VAT free treatment is based on exemption from VAT and/or “transfer of business” relief applying. VAT free treatment does not apply in all situations but exceptions are few ...
During the years of the recent property and development boom in the Turks and Caicos Islands (TCI), stamp duty on the real estate transactions became a substantial contributor to Government coffers. All real estate transactions in TCI are subject to stamp duty at varying rates depending on the size of the transaction and on the island on which the real estate is situate. In most cases, stamp duty is charged at the rate of 9.75% of the consideration passing ...
After lengthy discussions among regulators and politicians on ownership of commercial banks, Bank Indonesia issued its Regulation No. 14/8/PBI/2012 regarding Ownership of Shares in Commercial Banks (“BI Regulation No. 14”) which came into effect on 13 July 2012.In general, BI Regulation No. 14 provides rules that restrict ownership of commercial banks by individuals or corporations either on an individual or joint basis. BI Regulation No ...
The rules for the application for the tax amnesty program that were published on February 19, 2013 in the Federal Official Gazette provide that taxpayers wishing to benefit from the program must file an application online with the Tax Administration Service (“SAT” for its Spanish acronym) not later than May 31, 2013, through the SAT web page, although the Federal Revenue Law does not provide for an specific date for its application ...
The Philippine Supreme Court has issued a decision that may have a significant impact on how local nationality requirements (i.e., constitutional and statutory provisions requiring minimum Filipino ownership in certain industries) must be construed and applied. Enterprises such as telecommunications, media, advertising and land ownership are subject to such nationality requirements.The case of Gamboa v. Teves, et al. (G.R. No ...
With the ink now dry on The Taxpayer Relief Act of 2012 (passed in early 2013) which, among other things, raised the capital gains tax rate from 15% to 20% and the top income tax bracket of “high income” Americans from 35% to 39.6%, Senate Democrats have now proposed the “American Family Economic Protection Act” which defers the sequestration for the remainder of 2013 by (i) raising the income tax on millionaires ($55 billion over 10 years), (ii) increasing future military cuts ($27 ...
Contents Part XII.2 Tax Applicable to Trusts: a Potentially Expensive Tax Which Is Often Overlooked Application of the Anti-avoidance Rule in Subsection 83(2.1): Caution Is Required in the Context of the Acquisition of a Private Corporation Revenu Québec to Scrutinize Trusts Directors’ Liability for the Debts of a Corporation Payable to Employees for Services Rendered During the Directors’ Term of Office PART XII ...
The Committee on Foreign Investment in the United States The Exon-Florio Amendment to the 1988 U.S. Defense Production Act established the Committee on Foreign Investment in the United States ("CFIUS"). CFIUS is composed of representatives of several U.S. Government agencies, including the Departments of Treasury, State, Defense, Homeland Security, Labor and Commerce ...
It’s been well reported that Apple has managed to get a US trade mark registration for the layout or interior design (the look, if you like) of the Apple store. What this means is that Apple has exclusive rights to this layout - or indeed any confusingly similar layout - in the area of stores selling electronic goods ...
On 28 January 2013 the «Diário da República» (official gazette) published a set of measures1 - that came into force the following day - to improve and streamline the special scheme2 for granting a Portuguese ‘investment residence permit’ (“IRP”) to foreign nationals to enable them to make certain investments in the country ...
The Obama Administration has announced its intention of entering into negotiations with the European Union (“EU”) for a Transatlantic Trade and Investment Partnership (“TTIP”) aimed at achieving a substantial increase in transatlantic trade and investment between the world’s two largest economies. In the Federal Register of April 1, the United States Trade Representative solicited comments from the public with respect to U.S. negotiating objectives ...
Gift Tax Return Requirement for 2012 TransactionsDuring 2012, uncertainty about future estate and gift tax exemptions and rates led many of our clients to make substantial gifts during 2012 to their descendants or to trusts for descendants ...
Mobilizing the Money: A New Investment Program President Dilma Rousseff has launched an ambitious investment program in infrastructure, transport, logistics, and energy that will cost US$ 235 billion. The president and the entire government have been mobilized in the search for these investments, from domestic, foreign, public, and private sources ...
Increase in the Registration of Patents, Trademarks and Property Protected by Copyright - The various plans and the range of measures included in them that have been described have produced practical results, particularly an increase in the applications for registration of patents, trademarks and protection by copyright, specifically for property such as software. In terms of applications for patents registered in 2011, China came in first place above the USA and Japan ...
The Panamanian Limited Liability Partnership has been a part of Panama’s trade laws since 1916, when the Panamanian Commercial Code was issued. However, during 2009 it was subject to a profound reform in order to adapt it to an always demanding and changing market. As its “younger sister”, the worldwide famous “Sociedad Anonima” (1927), the limited liability partnership shall be filed at the Public Registry ...
The Alabama Department of Revenue (“Department”) recently issued a proposed regulation, Prop. Ala. Admin. Code 810-6-5-.05.02 which, if approved, will dramatically alter the obligation of sellers to collect and remit local sales and use tax imposed by Alabama cities and counties. By regulatory fiat, not supported by legislative changes, the Department seeks to reverse decades of tax history and positions ...
As of 15 May 2013, the most clicked legal resources from the SyCipLaw e-bulletins are:The International Comparative Legal Guide to: Telecoms, Media and Internet Laws 2013, Legal Bulletin: Technology, Media & Telecoms (Jan. 2013)The 2013 Foreign Investors' Guide to Real Estate Transactions in the Philippines ...
The Libyan Trade Mark Office (“LTMO”) has resumed the process of trade mark searching since April 2013 and will reportedly be accepting new applications for the registration of trade marks in May 2013. This after the LTMO had ceased its operations in January 2011 due to civil unrest in the country. There has, however, been some uncertainty with regard to the LTMO’s acceptance of new trade mark applications ...
The Comoro Islands, situated off the south-east coast of Africa, has ratified the Bangui Agreement, thereby becoming one of the 17 member countries of The African Intellectual Property Organisation (OAPI). The Bangui Agreement, once consented to, requires that the member states accede to the international treaties and conventions listed in the Agreement ...
Here are select February 2013 rulings of the Supreme Court of the Philippines on tax law: National Internal Revenue Code; documentary stamp tax; issuance of promissory notes; persons liable for the payment of DST; acceptance ...
