Although it is not often well-understood in business and tax circles, the Indian Act (the ?Act?), coupled with federal and provincial tax laws, provides several tax planning opportunities for Indigenous taxpayers. These laws provide various tax exemptions for people who qualify as ?Indians? under the Act, as well as for ?bands? and other ?councils ...
On December 19, Gabriel Boric was elected as future President of Chile, and will take office on March 11, 2022. The following is a list of the main tax proposals1 of the recently elected candidate: New income tax regime: a disintegrated income tax regime is proposed for large companies, separating the tax paid at the company level from the one payable by its shareholders when withdrawing profits ...
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 ...
Before 2018 comes to a close, it may be worthwhile to review the state of your tax, estate, and charitable giving plans. Along with the typical end-of-year considerations, this year it is crucial also to pay careful attention to the effects of the 2017 tax act (P.L. 115-97, signed into law on December 22, 2017, and informally called the “Tax Cuts and Jobs Act of 2017,” herein the “2017 Tax Act”) that altered many longstanding rules and assumptions ...
Congress recently enacted comprehensive tax reform (the “Act”). This memorandum highlights some of the provisions of the Act that are particularly relevant to U.S. multinational groups, with a focus on the provisions relating to income associated with intangible property, as defined for applicable U.S. federal income tax purposes. New Corporate Tax Rate The Act significantly changes the U.S ...
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 ...
On December 22, 2017, the president signed into law the Tax Cuts and Jobs Act (the Act). Effective Jan. 1, 2018, the Act represents the first major overhaul of the Internal Revenue Code in over 30 years ...
House Democrats recently released additional legislative proposals that, if passed, would affect several commonly used estate planning techniques. Among those proposals are three that would significantly impact some of the more common wealth transfer strategies. It is too early to tell whether this legislation has any chance of passing, but clients who are planning to use strategies that would be affected by these changes should watch carefully for future developments ...
Recently approved Cabinet Decision 85 of 2022 (the Decision) outlines the requirements and conditions for classification of persons as a “Tax Resident” of the UAE. We briefly outline below who qualifies as a UAE tax resident. Afridi & Angell have assisted a variety of clients in procuring tax domicile certificates and are well versed in the procedures and requirements ...
Under the wording of Art. 22 of the Business Freedom Act of 2 July 2004 in force until the end of 2016, in Poland a business making or accepting a payment worth in each instance over EUR 15,000 is required to route the payment through a bank account. The law imposes certain consequences for failure to comply with this requirement, primarily under the Foreign Exchange Law of 27 July 2002 and the Act on Combating Money Laundering and Financing of Terrorism of 16 November 2000 ...
What is important to consider? Many Ukrainian citizens are forced to stay abroad due to a full-scale Russian invasion. Some were there before the war and could not return, others had to leave Ukraine after February 24. It is clear that something is very difficult to predict at the moment and it can happen that, depending on your circumstances, your stay abroad can be long ...
A free transfer is when the donor (transferor) bestows a benefit or right without being paid, even though the transfer may be subject to the fulfillment of certain conditions, such as an inheritance, donation, or prize. The taxpayer in this type of conveyance is the party who accepts the benefit or right (transferee) since they receive an income. A donation deductible under article 39 of the Tax Agreement Law is exempt since it receives a different tax treatment ...
On 27 April 2023, the ECJ (Case C-537/20) ruled that Article 63 of the Treaty on the Functioning of the European Union (the “TFEU”) must be interpreted as “precluding legislation of a Member State which makes non-resident specialised property funds partially liable to corporate income tax in respect of the income from property which they receive in the territory of that Member State, whereas resident specialised property funds are exempted from that tax” ...
The EU is introducing an additional level of transparency in order to enhance the means tax authorities can use to detect potentially aggressive tax arrangements. In this light, EU Directive 2018/822/EU (hereinafter the “DAC 6”) imposes mandatory reporting of cross-border arrangements, affecting at least one EU Member State, that fall within one of a number of “hallmarks” ...
The SAT, Superintendecy of Tax Administration, has recently published the new procedure to request payment plans (agreements), via email. The procedure goes as follow: 1. Taxpayer should send an email to the email address correspondent to his fiscal address and region: Central Region: [email protected] Occidental Region: [email protected] Northeast Region: [email protected] South Region: [email protected] ...
SyCipLaw’s Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the last quarter of 2021. Please read the full text at https://tinyurl.com/SyCipLaw-DecTIPS-Int-Vol4-2 or https://tinyurl.com/SyCipLaw-DecTIPS-Int-Vol4-3. The SyCipLaw T.I.P.S - International Edition covers the top 10 tax issues of 2021: March 2021 1 ...
Treaties with Luxembourg and the Republic of Korea RatifiedSerbian Parliament ratified the double tax treaty with Luxembourg which was discussed in our recently published tax alert. If Luxembourg follow suit and ratifies the treaty this year it is likely that the treaty will be applicable from 1 January 2017.Parliament also ratified the double tax treaty with the Republic of Korea, signed in January this year. The treaty is based on the standard OECD Model Tax Convention ...
The SyCipLaw T.I.P.S. for October cover the following tax issues: 1. When the taxpayer cannot be located, what are the options available to a Revenue Officer in serving an electronic Letter of Authority? 2. Is the sale, barter, exchange or other disposition through Initial Public Offering of shares of stock in closely held corporations subject to tax? 3 ...
SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for October. The October 2023 issue covers the following tax issues: 1. In cases of real property taxes ("RPT") on land covered by the Torrens system, can treasurers of local governments rely on the certificates of title to determine the owner of the land for purposes of sending notices of deficiency RPT? 2 ...
SyCipLaw's Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the third quarter of 2023. Please read the full texthereor via thislink. The SyCipLaw T.I.P.S - International Edition covers the following tax issues: 1 ...
We've become familiar with the Met Office issuing “traffic light” warnings about potentially disruptive weather. Couples contemplating divorce or separation could face similarly rough going when it comes to their tax affairs, especially Capital Gains Tax (CGT) when property or a business is involved. The alert level right now would be considered “amber” - think before you separate as you might not be able to complete a settlement in time for this tax year ...
The Taxation Laws Amendment Bill 2016 has been released for public comment. It introduces various interesting amendments to South Africa’s tax law, which include the following: Use of trusts In circumstances where an interest-free loan has been advanced to a trust by a connected person (which includes a beneficiary or a relative of a beneficiary), it is proposed that a market-related rate of interest (currently 8%) is deemed to be paid on that loan ...
SyCip Salazar Hernandez & Gatmaitan (SyCipLaw) senior partner Carina "Caren" Laforteza and special counsel Catherina "Kate" Fernandez discuss the taxation of AI in light of recent developments concerning the concept of situs of taxation as interpreted by the Bureau of Internal Revenue (BIR), the local tax authority in the Philippines ...
Recently, in 2005, the Portuguese tax system streamlined its rules for the taxation of dividends, by harmonising rates which previously varied in accordance to the nature of the recipient of the dividends. This, along with the introduction of some provisions aimed at dealing with schemes that used exempt entities to evade tax, helped to turn the taxation of dividends more coherent and simple ...
Since we are in the season for the distribution of dividends, it is not without use to review and update, our last charter on this issue. It shall be recalled that in 2005 the Portuguese tax system streamlined its rules for the taxation of dividends, by harmonising rates which previously varied in accordance to the nature of the recipient of the dividends ...
