Section 64E(1) of the South African Income Tax Act, 1962 (the “Act”) provides that dividends tax must be levied at a rate of 20% of the amount of any dividend paid by any company, other than a headquarter company. In terms of section 64EA(a) of the Act, the beneficial owner of a cash dividend is liable for dividends tax in respect of that dividend. However, in terms of section 64F(1), a cash dividend is exempt from dividends tax in various instances ...
Attacks by the South African Revenue Service (“SARS”) on the transfer pricing practices of multinational enterprises (“MNEs”) are on the rise, leading to tax disputes with SARS over significant amounts of tax. MNEs operating in South Africa provide information to SARS in various forms such as annual Corporate Income Tax returns, Country-by-Country reports as well as the extensive Transfer Pricing documentation ...
Earlier this year, right in a last minute attempt to win undecided voters for one of the political parties, the leaving members of parliament enacted a new tax law. While fundamental changes to the Austrian Tenancy Law had been vividly discussed between the socialist and the conservative parties in recent years, the new law on the abolition of stamp duty falls completely short of what could have been achieved ...
On October 19, 2017, the IRS announced in Notice 2017-64 cost of living adjustments to the qualified plan dollar limits for 2018. Some of these limits did not change from 2017 because the increase in the cost of living index did not meet the statutory thresholds that trigger an adjustment. Below is a summary of the limits that are generally relevant for most retirement plans ...
The Tax Cuts and Jobs Act proposed by the House of Representatives last week would eliminate access to tax-exempt financing for 501(c)(3) organizations and for certain private borrowers by eliminating all private activity bonds, whether for new capital expenditures or for refinancing of existing bonds. Additionally, tax credit bonds could no longer be issued ...
Last week, the House Republicans unveiled their highly anticipated plan for tax reform. Although clients should not rush into planning based on the House plan, it is important to be aware of potential changes in the tax code. In particular, business owners and individual high net worth clients should be prepared for the adverse and beneficial aspects of the proposed plan because the plan is intended to be effective for tax years beginning January 1, 2018 ...
The UAE Ministry of Finance has announced the Executive Regulation for the Federal Decree-Law No. (8) of 2017 on Value Added Tax (UAE VAT Legislation) at a Cabinet meeting on 7 November 2017, headed by His Highness Sheikh Mohammed bin Rashid Al Maktoum, Vice President and Prime Minister of the UAE, Ruler of Dubai. It is expected that the Executive Regulation to UAE VAT Legislation will be released this week in draft form on both the UAE Ministry of Finance’s website (www.mof.gov ...
There are a number of considerations when relocating to another country that involve much more than a mere physical departure and the taking up of permanent residence in a foreign country. In South Africa, an individual will continue to be regarded as a South African resident for exchange control purposes until such time as the South African Reserve Bank (the “SARB”) has provided him/her with formal emigration approval ...
IRS Announcement 2017-15 provides relief to employees who have been adversely affected by the recent wildfires in Northern California by allowing them to take loans or distributions from retirement plans to alleviate hardships caused by the wildfires. The Announcement also provides relief from verification procedures required under retirement plans with respect to loans and hardship distributions ...
The new South African Taxation Laws Amendment Bill, 2017 (the “TLAB 2017”) was released following the public consultation process for the Draft Taxation Laws Amendment Bill, 2017 (the “Draft TLAB 2017”). While some of the changes in the TLAB 2017 following submissions made on the Draft TLAB 2017 are welcome, others are problematic ...
In terms of section 222(1) of the South African Tax Administration Act, 2011 (the “TAA”), “[i]n the event of an ‘understatement’ by a taxpayer, the taxpayer must pay, in addition to the ‘tax’ payable for the relevant tax period, the understatement penalty determined under subsection (2) unless the ‘understatement’ results from a bona fide inadvertent error” (our emphasis) ...
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 ...
At the end of the day, budgets always reflect the political climate of the country. The Chancellor is a member of a government unable to command a majority without the support of the DUP, which has lost two cabinet ministers in the last month, is subject to various manifesto commitments regarding not raising taxes, and that is facing the monumental economic uncertainty of leaving the EU in the next 18 months ...
On December 22, 2017, President Trump signed into law a sweeping tax act now known as An Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018 (the “Tax Cuts and Jobs Act”). The Tax Cuts and Jobs Act is effective beginning with the 2018 tax year. Over the coming weeks, we will be alerting you to changes in the tax law and planning ideas that may help to minimize your taxes ...
The Tax Cuts and Jobs Act (the "TCJ Act") signed into law by President Trump on December 22, 2017, creates sweeping changes in the way individuals and businesses are taxed. One of the most important changes involves the taxation of pass-through entities and directly implicates the standards for qualified small businesses stock ("QSBS") under IRC section 1202 ...
The tax reform bill passed by Congress at the end of 2017 significantly reduces the number of taxpayers whose families will pay gift tax or estate tax, but it comes with an “expiration date” of December 31, 2025. Prior to the Tax Cuts and Jobs Act (the Act), an individual could transfer up to $5,490,000 ($10,980,000 for a married couple) without paying estate, gift, or generation-skipping transfer (GST) taxes ...
The UAE Ministry of Finance released Cabinet decision No. 59 specifying all Designated Zones be effective the begining of 2018 for the purposes of implementing the Designated Zone provisions in Federal Decree Law No 8 on Value Added Tax. The Cabinet has the authority to amend the list of Designated Zones as required ...
In case you have been in a coma, major tax changes to the Internal Revenue Code were passed in December 2017. See Pub. L. 115-97 (115th Cong., 1st Sess.). Those changes make it much more attractive (from a tax perspective) to arrange one’s affairs like a business owner. Broadly speaking, the new tax law changed the landscape so that many business owners will now benefit from dramatically lower tax rates (e.g., the corporate rate has not been this low since 1939) ...
This is a reminder to all corporations whose employees or former employees exercised an incentive stock option or made a purchase under the corporation's employee stock purchase plan (ESPP) in 2017 ...
The 2017 tax reform act referred to as the Tax Cuts and Jobs Act (Act) was signed into law Dec. 22, 2017. The law affects executive compensation and employee benefits in several ways. This alert provides a brief overview of some of the changes. Executive Compensation New private company deferral opportunity for qualified stock awards. The Act contains new Internal Revenue Code Section 83(i), which provides a deferral opportunity for non-executive employees of privately held companies ...
In recent months the Serbian Parliament passed amendments to Serbian tax laws, including the Law on Personal Income Tax (PIT Law), the Law on Contributions on Mandatory Social Insurance (CMSI Law), the Law on Corporate Income Tax (CIT Law), and the Law on Value Added Tax (VAT Law). These amendments introduce tax relief for salaries paid to employees in newly incorporated legal entities ...
Under the Affordable Care Act (“ACA”), large employers (generally those with 50 or more full-time employees or full-time equivalents) must report annually to the IRS information about the health coverage offered to their full-time employees during the prior year using IRS Form 1095-C. The IRS uses the forms to assess whether an employer "shared responsibility" penalty applies. Employers also must provide copies of the forms to their full-time employees ...
Since 1 January 2013, section 19 of the Income Tax Act, 1962 (the “Act”) and paragraph 12A of the Eighth Schedule to the Act (the “Eighth Schedule”) have determined the tax implications where a debt owing by a taxpayer is cancelled, waived, forgiven or discharged for no consideration (or for consideration that is less than the amount of the debt) ...
