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 ...
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
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 ...
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 ...
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 ...
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 ...
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 ...
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 ...
Entity classification refers to a set of rules used in the U.S. tax system to classify entities for the purposes of the Internal Revenue Code. Once classified, the entity will either be subject to the Code rules for corporations or the Code rules for partnerships. The Canadian tax system, on the other hand, does not have entity classification rules. Instead, the Canadian tax system simply categorizes entities for tax purposes based on their classification under commercial law ...
These days the Ministry of Taxation is leading a crusade against Danish companies that have omitted to withhold tax at source in connection with the payment of dividend or interest to intermediary holding companies abroad. It is claimed that the companies are liable for the tax that has not been withheld ...
In late August, Hurricane/Tropical Storm Irene ripped through much of the East Coast leaving a wake of storm and flood damage. Parts of North Carolina, Maryland, New York, New Jersey, Pennsylvania, New Hampshire, Massachusetts, Connecticut, Vermont and Puerto Rico have been declared federal disaster areas by the president. The specific counties of each state and territory that have been declared federal disaster areas are available here ...
Contents To Include: i) Engaging in Activities as a Dealer or Adviser: Am I Required to Register? ii) A Corporation’s Unanimous Shareholder A greement Now Available to its Creditors iii) Invoices of Convenience and Accommodation iv) The Importance of Written Contracts Respecting Intellectual Property or the Art of Leaving Traces ENGAGING IN ACTIVITIES AS A DEALER OR ADVISER: AM I REQUIRED TO REGISTER?Josianne Beaudry jbeaudry@lavery ...
A new change in the Italian regulation of the industrial design has been recently introduced by section 8, paragraph 10, of Law Decree no. 70 of May 13, 2011 (“First urgent provisions for the economy”), aimed at restricting the temporary protection granted to industrial design works under copyright law under section 239 of the Industrial Property Code (Legislative Decree no. 30 of February 10, 2005, as amended by Legislative Decree no ...
Texas has now joined the growing ranks of states that have passed laws aimed at increasing tax collection from online retail transactions. Although Governor Rick Perry vetoed an earlier bill (H.B. 2403) providing that out-of-state retailers that have relationships with certain Texas “affiliated” entities will be deemed to be doing business in Texas for purposes of the sales and use tax, language virtually identical to that found in H.B. 2403 is included in S.B ...
FOREIGN REPORTING: A COSTLY OVERSIGHT - Tax authorities have developed various means of verifying international structures. More specifically, these compliance tools take the form of information returns which target operations involving non-residents and foreign property held by certain Canadian taxpayers. Although the requirement to file these returns has been in existence for many years, taxpayers and sometimes their advisers seem to be unaware of them ...
I. INVESTING EM ANGOLA TODAY: INTERNATIONAL TAX MANAGEMENT At times the interest Portuguese companies have in the Angolan market has lived alongside the fear that there are factors that discourage investment in the country. In contact with businesspeople linked to a wide variety of sectors, we have been able to witness on the one hand, demonstrations of high levels of motivation and, on the other hand, signs of scepticism as to what the virtues of investing in Angola may be ...
What are the current gift tax rules and what will happen in 2013? Prior to January 1, 2011, the gift tax exemption was $1,000,000, meaning you could give away $1,000,000 over the span of your life without having to pay a gift tax. For 2011 and 2012, you can give away up to $5,000,000 without a gift tax. That is five times the amount previously allowed. If the aggregate amount of your gifts exceeds $5,000,000, the gift tax rate during 2011 and 2012 is 35% (reduced from 45% in 2009) ...
The IRS has apparently increased its focus on unrelated business taxable income (“UBTI”) of tax-exempt organizations. At a conference last month, IRS officials indicated they are looking closely at UBTI in all contexts with respect to exempt organizations, including conducting a long-term study on college and university treatment of UBTI ...
With the U.S. economy not as robust as it once was, it seems that Americans are currently more interested in selling their Canadian assets, particularly recreational property, than buying Canadian assets. It is therefore useful to consider the issues that arise when a U.S. person sells Canadian real estate. The following points are relevant: The U.S ...
On May 4 2011 the Ministry of Finance of the Russian Federation published on its website the draft law on transfer pricing, which includes the amendments introduced after the first reading held o February 19, 2010 ...
The interaction between the Treaty and Uruguayan tax rules Permanent establishment (Pe)1 and Fixed base for business (Fbb)2 The concept of permanent establishment3 for corporate activity, and the concept of a fixed base for business4 for independent individual workers establish the mechanism for apportionment of tax-raising powers between both countries for income of a nature defined in those countries ...
It currently appears that Texas may join a growing number of states that have passed laws aimed at increasing tax collection from online retail transactions. On Wednesday, April 27, 2011, the Texas House passed H.B. 2403, which provides that out-of-state retailers that have relationships with certain Texas “affiliated” entities will be deemed to be doing business in Texas for purposes of the sales and use tax. H.B. 2403 will now be sent to the Texas Senate for consideration ...
