The Ministry of Finance and the State Administration of Taxation jointly issued the Notice on the Issue of the Levy of Individual Income Tax on Income Derived by Individuals from Stock Options on 31 March 2005 ("Notice"). The Notice, which entered into effect on 1 July 2005, provides a number of guidelines regarding the taxability of such schemes. Taxable event The Notice applies to stock options granted to employees of listed companies or their holding companies ...
Per China’s WTO commitments, the China Insurance Regulatory Commission issued the Announcement Regarding Permitting Foreign Insurance Brokerage Companies to Establish Wholly Foreign-owned Insurance Brokerage Companies on 11 December 2006 ...
In Commissioner of Internal Revenue v Ruben U Yu,(1) the Court of Tax Appeals (CTA) en banc clarified that the 180-day period referred to in section 228 of the Tax Code, as amended, applies only to the period within which the Commissioner of Internal Revenue (CIR), or their duly authorised representative, may act on a protest against a tax assessment ...
On April 29, 2020, the Chilean IRS issued instructions regarding the tax treatment of expenses incurred in connection with the health emergency caused by Covid-19. Additionally, the Tax Authority refers to the general requirements for all expenses and the tax treatment of some donations. I. Regarding the general requirements on deduction of expenses In accordance with Article 31 of the Income Tax Law, recently amended by Law No ...
On May 25, 2020, the Chilean IRS issued instructions on the temporary decrease to 0% of the Stamp Tax rate accrued between April 1 and September 30, 2020 (the "0% Rate Term"). In general terms, the Circular establishes the following: Although this is a transitory decrease, it benefits extensions and renewals made during the 0% Rate Term, which are linked to documents originally granted and taxed. This represents a change of criteria by the Chilean IRS ...
In this context, the judgements provide useful guidance on the concepts of abuse and beneficial ownership. Abuse concept According to the CJEU, it is settled case-law that there is, in EU law, a general legal principle that EU law cannot be relied on for abusive or fraudulent ends ...
In early 2022, the Autorité des marchés financiers (the AMF) conducted specific consultations on financial products offered on the Internet. Further to these consultations, the AMF published explanations on the Regulation respecting Alternative Distribution Methods (the RADM) in late December 2022 ...
On November 2, 2023, in response to certain controversy, the Canada Revenue Agency (?CRA?) sought to clarify the application of the new disclosure rules, in force since June 22, 2023. The CRA?s comments relate, in particular, to the impact of reporting obligations on severance agreements, a topic we initially covered a few weeks ago1. We believe it is appropriate to go over these clarifications ...
The impact of the novel coronavirus (COVID-19) across the globe remains a significant concern in every aspect of business – and the representation and warranty (R&W) insurance market is no different. The following Frequently Asked Questions are designed to address some of the more common questions that have arisen since the outbreak of the pandemic.As always, advice in this area is fact-sensitive ...
If you are a U.S. business with international operations, here are four questions you should consider: Does your company have more than two foreign subsidiaries, at least one of which is profitable? Do you have a profitable foreign subsidiary that guarantees any U.S. debt? Are you considering the purchase of a company located outside the U.S.? Does your U.S ...
This is a briefing on the issuances as of July 22, 2020 on the following matters in relation to the COVID-19 pandemic: A. Intellectual Property Office (IPOPHL) Suspends Services at its Main Office from July 20 to 27, and Extends Deadlines B. BIR Amends Reportorial Requirements of Banks and Other Lenders that Granted a Grace Period on Loans that were due during the Enhanced Community Quarantine C. New Bureau of Internal Revenue (BIR) Form for Related Party Transactions A ...
The window period for South African residents to regularise their unauthorised foreign assets under the Special Voluntary Disclosure Programme (“SVDP”) closes on 31 August 2017. The current SVDP is the latest in a series of such opportunities offered by the Financial Surveillance Department of the South African Reserve Bank (“SARB”), beginning with the 2003 exchange control amnesty ...
On April 8, 2021, the Center for Medicare & Medicaid Services (“CMS”) announced a proposed rate increase of 1.3 percent for skilled nursing providers in fiscal year 2022. It is estimated this will result in approximately $444 million increase in payments to skilled nursing facilities (SNF) under Medicare Part A for the fiscal year. This increased payment rate does not incorporate the SNF Value-Based Program (VBP) reductions that CMS estimates to be $184 ...
In a letter to state Medicaid directors on Nov.13, 2018, the Secretary of the U.S. Department of Health and Human Services, Alexander Azar, announced a new demonstration opportunity that will allow states to provide improved care for adults with a serious mental illness (SMI) and children with serious emotional disturbance (SED) ...
In times of emergency, the Secretary of Health and Human Services (the "Secretary") has authority to issue temporary waivers or modifications of certain Medicare, Medicaid, CHIP, and HIPAA requirements. The Centers for Medicare and Medicaid Services ("CMS") has released a substantial number of waivers in response to the coronavirus national emergency ...
In December 2018, Part I of this column was based on the Proposed 199A Regulations1 and included the applicable definitions and the basic concepts and mechanics of the 199A 20% deduction of Qualified Business Income (“QBI”) up to the 20% of the excess of the taxpayer’s taxable income over the taxpayer’s net capital gain ...
The Commission for the Financial Market (“ CMF ”), on May 28, 2020, has issued the Official Letter No. 22,260 (the “ Official Letter ”) in response to the pronouncement request sent by the Treasury Minister of the Chilean Government, Mr Ignacio Briones Rojas, to clarify the scope of the enforcement and the effects of the new article 30 of Law No. 21,227, which empowers the access to the unemployment insurance benefits provided in Law No ...
Each of the Common Monetary Area (CMA) Member States presented their 2014/15 Budgets during February 2014. An overview of the Budgets of Lesotho, Namibia and Swaziland reveals Namibia as the only country proposing fiscal amendments of any significance. A common theme of these Budgets is a concern about the increased uncertainty regarding the future of the South African Customs Union (SACU) and a firm intention to reduce reliance on SACU revenue ...
The Gambling Policy Division of the Irish Department of Justice has joined 14 other gambling regulators from around the globe in signing an International Declaration expressing concern about gambling in video games. The regulators presented a united front in addressing the "blurring of lines between gambling and other forms of digital entertainment". The increasing presence of gambling in the video gaming world has been raised as a growing concern ...
Following the Luxembourg case C-274/15, the series of cases relating to the scope of the cost-sharing VAT exemption also referred to as “Independent Group of Persons” (“IGP”) continues with the release today of three judgements by the Court of Justice of the EU (“CJUE”): Aviva (C-605/15), DNB Banka (C-326/15) and European Commission v Federal Republic of Germany (C-616/15) ...
