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PLMJ | June 2013

Law   55-A/2012   of   29   October   – published last year as part of the package of measures to combat the financial crisis – made ownership, use or surface rights of residential urban properties with an official taxable value (valor patrimonial  tributário) equal to or greater than EUR 1 million subject to Stamp Duty, calculated  at the rate of 1% ...

Misick and Stanbrook | June 2013

In the clearest sign yet that some buoyancy has returned to the TCI real estate market, the TCI Government has announced changes to TCI’s stamp duty regime ...

Lavery Lawyers | June 2013

CONTENTS  Life Insurance Policy: How to Extract Funds from a Corporation with No Tax ImpactConstructive Dismissal Analyzed in the Context of a Business AcquisitionThe Right of Withdrawal, a Controlled Form of Contractual FreedomTransfers of Residences Involving a Spousal Testamentary Trust LIFE INSURANCE POLICY: HOW TO EXTRACT FUNDS FROM A CORPORATION WITH NO TAX IMPACTLuc Pariseau with the collaboration of Martin Bédard, articling studentIndividual shareholders who wish to withdraw

Here are select February 2013 rulings of the Supreme Court of the Philippines on tax law:  National Internal Revenue Code; documentary stamp tax; issuance of promissory notes; persons liable for the payment of DST; acceptance ...

Waller | May 2013

The Alabama Department of Revenue (“Department”) recently issued a proposed regulation, Prop. Ala. Admin. Code 810-6-5-.05.02 which, if approved, will dramatically alter the obligation of sellers to collect and remit local sales and use tax imposed by Alabama cities and counties. By regulatory fiat, not supported by legislative changes, the Department seeks to reverse decades of tax history and positions ...

Morgan & Morgan | May 2013

The Panamanian Limited Liability Partnership has been a part of Panama’s trade laws since 1916, when the Panamanian Commercial Code was issued. However, during 2009 it was subject to a profound reform in order to adapt it to an always demanding and changing market. As its “younger sister”, the worldwide famous “Sociedad Anonima” (1927), the limited liability partnership shall be filed at the Public Registry ...

Haynes and Boone, LLP | April 2013

Gift Tax Return Requirement for 2012 TransactionsDuring 2012, uncertainty about future estate and gift tax exemptions and rates led many of our clients to make substantial gifts during 2012 to their descendants or to trusts for descendants ...

Lavery Lawyers | March 2013

Contents Part XII.2 Tax Applicable to Trusts: a Potentially Expensive Tax Which Is Often Overlooked Application of the Anti-avoidance Rule in Subsection 83(2.1): Caution Is Required in the Context of the Acquisition of a Private Corporation Revenu Québec to Scrutinize Trusts Directors’ Liability for the Debts of a Corporation Payable to Employees for Services Rendered During the Directors’ Term of Office PART XII ...

Waller | March 2013

With the ink now dry on The Taxpayer Relief Act of 2012 (passed in early 2013) which, among other things, raised the capital gains tax rate from 15% to 20% and the top income tax bracket of “high income” Americans from 35% to 39.6%, Senate Democrats have now proposed the “American Family Economic Protection Act” which defers the sequestration for the remainder of 2013 by (i) raising the income tax on millionaires ($55 billion over 10 years), (ii) increasing future military cuts ($27 ...

The rules for the application for the tax amnesty program that were published on February 19, 2013 in the Federal Official Gazette provide that taxpayers wishing to benefit from the program must file an application online with the Tax Administration Service (“SAT” for its Spanish acronym) not later than May 31, 2013, through the SAT web page, although the Federal Revenue Law does not provide for an specific date for its application ...

Misick and Stanbrook | February 2013

During the years of the recent property and development boom in the Turks and Caicos Islands (TCI), stamp duty on the real estate transactions became a substantial contributor to Government coffers. All real estate transactions in TCI are subject to stamp duty at varying rates depending on the size of the transaction and on the island on which the real estate is situate.  In most cases, stamp duty is charged at the rate of 9.75% of the consideration passing ...

A&L Goodbody LLP | February 2013

Acquiring investment property This alert is intended to highlight certain VAT issues relating to the purchase and management of property which is subject to a lease(s). In general VAT should not be chargeable on the sale of such property. Depending on the circumstances this VAT free treatment is based on exemption from VAT and/or “transfer of business” relief applying. VAT free treatment does not apply in all situations but exceptions are few ...

World Services Group | February 2013

The Philippine Securities and Exchange Commission (SEC) issued Memorandum Circular No. 1, s. 2013 dated 7 January 2013, requiring the incorporation of the tax identification number (TIN) of foreign investors in all forms papers and documents filed with the SEC ...

Garrigues | February 2013

1. Interest on Equity and Dividends: the Brazilian Perspective Brazilian companies have two main instruments for remunerating shareholders for the  capital invested in companies: dividends and interest on net equity (“Juros sobre o capital própio”, referred to as “IoNE” in this article). Both instruments can be used at the same time, but their tax treatment will depend on the particular characteristics of  each case ...

Haynes and Boone, LLP | January 2013

On January 14, 2013 the United States and Spain signed a new protocol (the “Protocol”) amending the existing income tax treaty between the United States and Spain that was signed on February 22, 1990 (the “Treaty”). The Protocol modernizes the Treaty to conform with the existing treaty policies of both the United States and Spain. Key provisions of the Protocol include: Exclusive residence-state taxation (i.e ...

Wardynski & Partners | January 2013

Key principles approved by the Polish Council of Ministers - On 16 October 2012, the Polish Council of Ministers approved key assumptions for the long-awaited shale gas production and taxation legislation. The assumptions, which impact both conventional and unconventional oil and gas production, have in particular, been awaited by the developing shale gas sector and investors interested in joining this brand new market. ...

Waller | January 2013

In re: Signal Mountain Cement Company – Assessment Appeals Commission Upholds Assessor’s Use of “Value in Use” Methodology for Standard Valuation of Tangible Personal Property in Tennessee but Affirms Taxpayer Use of “Fair Market Value in Exchange” Methodology in Nonstandard Valuations ...

Haynes and Boone, LLP | January 2013

After all of the sand had run out of the hourglass, Congress finally passed (and the President signed) a compromise tax bill to avoid very substantial income tax increases on taxpayers with income under $400,000 ($450,000 for joint filers). The good news for our estate planning clients is the “permanent” extension of the current estate, gift, and generation-skipping transfer tax exemptions, and a slight increase in the tax rate from 35% to 40% ...

Krogerus | January 2013

This is an important year on the taxation front. New rules restrict interest deductions and increase the transfer tax related to the sale of shares in housing and real estate. Additionally, two tax incentives support research and development activities, as well as innovation and growth. Restriction on interest deductionThe Finnish legislature has restricted interest deductions applied in taxation starting in the 2014 taxation year ...

Waller | January 2013

The so-named “American Taxpayer Relief Act,” now signed by the President after having been passed in the wee hours by the Senate on January 1, 2013, and later that day by the House, may pull the country back from a self-created fiscal/political ditch, but leaves the country at the edge of a fiscal cliff with spending cut issues, debt ceiling issues and undoubtedly more tax issues to be dealt with before March 1, 2013. Overview ...

The 2013 Federal Revenue Law was published yesterday and its Transitional Article 3 includes an amnesty covering payment of federal taxes and related government charges, as follows: a)  80% forgiveness of tax assessment consisting of federal taxes, antidumping duties, and fines for failure to comply with federal tax obligations, other than payment obligations, arising prior to January 1, 2007 ...

Haynes and Boone, LLP | November 2012

You are general counsel of a publicly traded medical device company that has begun the diligence process on your company’s target, a publicly held x-ray and CT scan component manufacturer. The target is a Delaware corporation based in California, with additional manufacturing facilities in Utah and Kentucky; within the past three years, it has sold two mothballed manufacturing facilities ...

ENSafrica | November 2012

Supreme Court of Appeal tax cases often adopt a higher-than-normal threshold to support an exemption from, or a relaxation of, taxation. This is normally expressed as a rule that tax concessions are to be strictly construed ...

Waller | November 2012

The IRS plans to begin recurring market segment examination of tax-exempt bonds, including the hospital market, according to statements made by Bob Griffo, Supervisory Tax Law Specialist with the Internal Revenue Service (IRS), at a recent National Association of Bond Lawyers conference. For the first year of the program, the IRS plans to examine between 20 to 40 tax-exempt hospitals ...

Alta QIL+4 ABOGADOS | November 2012

On Wednesday, October 3rd.,  it was published in the Official Gazette the provisional suspension issued by the Constitutional Court of  Section 180, 4.,  of  Decree 10-2012 which abrogated the withholding exemption contained in Section 12 of Decree 80-2000 ...

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