On Friday December 17, 2010, the President signed into law the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the “Act”). Many taxpayers were keeping an eye on this legislation because of the possible impact it might have on year-end tax planning. Specifically, taxpayers were keen to find out if certain favorable tax laws would be extended. Many of the tax laws that were scheduled to sunset were extended for an additional two years ...
By Vitas Vasiliauskas, Associate Partner of the law firm LAWIN Lideika, Petrauskas, Valiûnas ir partneriai In December 2010, the most important legislative acts on taxation to be enacted in 2011 were publicised ...
Marriage has become as globalized as business today. If one spouse is a non-citizen, there are some minor challenges in drafting estate planning documents to minimize United States estate taxes, and we recommend consulting with counsel in the non-citizen’s home country. If the non-citizen’s family has substantial wealth, there are opportunities to reduce, or even eliminate, U.S. estate and gift tax on transfers to that individual ...
In prior years, certain tax-exempt organizations whose gross receipts did not normally exceed $25,000 were exempt from filing the standard Form 990. Now, this threshold is $50,000, and for tax years beginning on or after January 1, 2010, such organizations must submit a Form 990-N “e-Postcard” annually (rather than the Form 990-EZ or Form 990 required of larger organizations). Private foundations and supporting organizations may not file the Form 990-N ...
The last minute compromise which averted the expiration of the Bush tax cuts included a two-year modification of the estate, gift, and generation-skipping taxes. For 2011 and 2012, every individual will have a $5 million gift tax exemption. For individuals dying in 2011 or 2012, the estate tax exemption is also $5 million, and the generation-skipping transfer (“GST”) tax exemption for transfers during life or at death is $5 million ...
On February 8, 2011, the IRS announced a second voluntary disclosure program that will allow U.S. taxpayers to disclose offshore accounts that were previously kept secret from the IRS. U.S. citizens and resident foreign nationals are required to pay U.S. federal income tax on their worldwide income. The objective of this initiative is to bring taxpayers that have used undisclosed foreign accounts to avoid or evade taxes into compliance with United States tax laws ...
Recently, the Exempt Organizations Office (“EO”) of the IRS released a list of 2011 initiatives, including international activities and compliance. The following are just a few of the items on the IRS’s radar for the coming year. Employment Tax Examinations. In 2011, the EO plans to conduct full examinations of 500 exempt organizations to determine compliance with employment tax rules as part of a project reviewing employment tax practices of both taxable and tax-exempt organizations ...
These days many US businesses are looking north to Canada for new markets. This paper discusses when a US business needs to worry about the Canadian tax system. The short answer comes from some of the oldest provisions in the Income Tax Act. US businesses need to worry about Canadian tax when they have a physical presence in Canada. To read this paper, click here. For more information please contact Len Glass at [email protected] or 604.631.9140 ...
* The New Act Respecting the Legal Publicity of Enterprises and Trusts * New Filing Requirements for Partnerships * Requests for Production of Documents by the Tax Authorities * Your’re Fired!: The Impact on the Exercise of Stock Options THE NEW ACT RESPECTING THE LEGAL PUBLICITY OF ENTERPRISES AND TRUSTS André Paquette apaquette@lavery ...
Contents* Major Relief for Non-Residents of Canada * A New act on Legal Publicity * Stock options Can Be advantageous, But Be Careful! * Adoption of IFRS and Recent GaaP Changes: The impact on Credit agreements MAJOR RELIEF FOR NON-RESIDENTS OF CANADAPhilippe Asselinpasselin@lavery ...
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 ...
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 ...
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 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 ...
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) ...
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 ...
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 ...
These Regulations transpose the EU Directive 2008/101/EC ("the Aviation Directive") which extends the EU Emissions Trading Scheme ("ETS") to aviation activities. The previous 2009 Regulations [S.I. No. 274 of 2009], which partially transposed the Aviation Directive, are revoked. All flights arriving at and departing from EU airports will be included in the ETS from 2012 ...
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 ...
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 ...
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 ...
bold">This paper considers the recent developments in Nigerian Ship Arrest Law. The Admiralty Jurisdiction Procedure Rules (AJPR) 2011 for the Federal High Court of Nigeria (FHC), and its effect on ship arrest practice. bold">The new AJPR 2011 (the New Rules) was made by the Chief Judge of the FHC(CJF) 1 on 1st March 2011 and came into force on 14th March 2011 ...
