The Tax Administration Act 28 of 2011 (“Tax Administration Act”) came into effect on 1 October 2012 (save for certain provisions that are still to come into force). This important piece of legislation seeks to incorporate into one Act all those administrative provisions (except for customs and excise) that are generic to all tax Acts and that were previously duplicated across all the different tax Acts ...
The Internal Revenue Service (IRS) has introduced a new, shorter form of the exemption application for Section 501(c)(3) status—the Form 1023-EZ. Previously, most organizations seeking federal income tax exemption under Section 501(c)(3) were required to complete the full 26-page (plus attachments) Form 1023, regardless of their anticipated funding or the complexity of their activities ...
The Internal Revenue Service (“IRS”) recently issued Revenue Ruling 2014-18 (the “Ruling”) allowing the deferral of compensation from offshore hedge funds through the use of stock options (“Options”) and stock-settled stock appreciation rights (“SARs”) without running afoul of Section 457A of the Internal Revenue Code (“Section 457A”) ...
The Budget Plan unveiled by the Quebec Government as part of the Budget Speech of last June 4 includes many initiatives to increase venture capital financing. The 2014 2015 Budget presented by the Minister of Finance, Carlos Leitão, provides for several measures to make $560 million available to finance businesses and venture capital funds, including the establishment of a $375 million fund to invest in venture capital funds ...
A Taxpayers’ Charter setting out the rights and obligations of taxpayers in South Africa was published for the first time during 1997. That Charter contained a statement of intent insofar as taxpayers’ rights in South Africa is concerned. On 19 October 2005 the SARS Client Service Charter was released setting out the levels of service that taxpayers could expect in their dealings with the South African Revenue Service (‘SARS’) ...
Possession, as they say, is nine tenths of the law. Generally in commercial litigation where, for example, a claim for an outstanding amount is brought against a party, such party is not required to make payment to the claimant until a court has adjudicated on the matter. However, when it comes to matters of tax, the Tax Administration Act, No ...
Foreign investors in Australian entities may be unaware that in some circumstances the Australian Taxation Office (ATO) can assess them for Australian tax on gains made from the sale of their investment. The circumstances in which tax can arise are described in this article. In addition, law changes are proposed which (amongst other matters) would, from 1 July 2016, require purchasers to withhold 10% from the purchase price and pay that to the ATO in some circumstances ...
Yesterday, July 22, 2014, the Senate Finance Committee held a hearing at which the so-called corporate inversions of U.S. multinationals were a key topic. The hearing followed U.S. Treasury Secretary Jacob Lew’s July 15 letter to congressional tax writers urging immediate legislative action to stop corporate inversions of U.S. companies. Generally, a corporate inversion is a transaction in which a U.S. multinational group with a U.S. parent corporation restructures so that the U.S ...
It is no hidden secret that unemployment in South Africa remains considerably high. According to the World Economic Forum Global Risk 2014 Report, structural unemployment and underemployment appears second overall in the Ten Global Risks of Highest Concern as many people in both advanced and emerging economies struggle to find jobs. The youth and minorities are especially vulnerable ...
On 25 July 2014, Cyprus signed and ratified an Agreement for the avoidance of double taxation with the Swiss Confederation, with respect to Taxes on Income and on Capital, as well as the relevant Protocol. The Agreement will contribute to the further development of trade and economic relations between Cyprus and the Swiss Confederation, as well as other countries ...
On 3 August 2014, Law of Ukraine "On Amending the Tax Code of Ukraine and Certain Other Legislative Acts of Ukraine" No. 1621-VII which was adopted on 31 July 2014 for creating conditions to increase financial inflow into the state budget (the "Law"), came into force. Implementation of the proposed regulations will provide a possibility to boost in 2014 the resources of Ukraine's unified budget for nearly UAH 10.3 bn ...
The World Pension Summit (Africa), first of its kind in Africa, was hosted in Abuja on 7 and 8 July 2014. The summit focused on African developments in the pension industry and coincided with the 10th anniversary of the pension reform in Nigeria that led to the enactment of the Pension Reform Act No 2 of 2004 (“the 2004 Act”) ...
Under the provisions of the Tax Administration Act, the Commissioner: South African Revenue Service (‘SARS’) is entitled to request that a taxpayer submits relevant material that SARS requires in terms of section 46 of the Tax Administration Act No. 28 of 2011 (‘TAA’). Section 1 of the TAA in turn defines ‘relevant material’ as meaning: “any information, document or thing that is foreseeably relevant for the administration of a Tax Act as referred to in section 3 ...
The implications of FATCA in South Africa (written exclusively for Bloomberg BNA, Tax Planning International, European Tax Service, volume 16, number 7, July 2014) Written by Hanneke Farrand, director, and Caroline Rogers, senior associate, both in the tax department at ENSafrica. I. Background The Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the USto target non-compliance by US taxpayers using foreign accounts ...
Recently, there have been indications that the Israel Tax Authority (the "ITA") is strengthening its ties with foreign tax authorities and banks in order to obtain information on Israelis who hold unreported bank accounts overseas ...
Those words were written nearly a decade ago and described, in brief, the complicated and confusing legal world of wills, estates and succession. The Report from which that quote comes recommended a wholesale overhaul of this area of the law. The B.C. Legislature, various interest groups and the legal community have been working on such a revision to this area of the law since ...
The approval of amendments to the Tax Code and the creation of new taxes have caused upset and criticism among business sectors in El Salvador, accusations that they will affect competitiveness and a better economic performance, and lead to an increased cost of living ...
Recent press speculation suggests that Entrepreneurs Relief may be a victim of its own success and could be restricted or even removed. For the individual entrepreneur and for SME Britain more generally such a change would be little short of disastrous.Entrepreneurs Relief has been a key source of oxygen for our anaemic economy over recent years ...
If a Code Section 501(c)(3) organization (501(c)(3)) or State or local government (collectively Exempt Entity) hospital or other facility financed with tax-exempt bonds has “too much” private business use of such facility, the bonds will lose their exempt status. Various arrangements, including partnerships or management agreements with non-exempt persons can constitute private business use ...
In recognizing the serious humanitarian crisis and potential health ramifications to the population of the United States and the World, the IRS announced on Thursday, October 29, 2014, in a pair of Notices that the Ebola outbreak occurring in the Western Africa countries of Guinea, Liberia, and Sierra Leone is a qualified disaster for certain purposes of the Internal Revenue Code ...
Introduction: As noted in our earlier article, foreign investors in Australian entities may be unaware that in some circumstances the Australian Taxation Office can assess them for tax on gains made from the disposal of their Australian investments. In particular, a foreign investor will be liable to Australian tax where they make a gain on the disposal of taxable Australian property ...
Professionals dealing with secured lending in Belgium have been looking forward for some time to the new Belgian law of 11 July 2013 on security interests over movable goods (“Wet van 11 juli 2013 tot wijziging van het Burgerlijk Wetboek wat de zakelijke zekerheden op roerende goederen betreft en tot opheffing van diverse bepalingen ter zake” / “Loi du 11 juillet 2013 modifiant le Code civil en ce qui concerne les sûretés réelles mobilières et abrogeant diverses dispositions en cette matiè
