If you are a U.S. business with international operations, here are four questions you should consider: Does your company have more than two foreign subsidiaries, at least one of which is profitable? Do you have a profitable foreign subsidiary that guarantees any U.S. debt? Are you considering the purchase of a company located outside the U.S.? Does your U.S ...
On 23 March 2010, Indonesia and Hong Kong signed a new agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (“Tax Treaty”). To date, the Tax Treaty has not yet been ratified by either country. It is expected that the Tax Treaty will come into force in early 2011 following its ratification ...
The report of the Henry Review of the Australian taxation and transfer system released on 2 May 2010, entitled 'Australia's Future Tax System' (the Report) is the 'root and branch' review into the taxation and transfer system proposed by the Australian Labor Party at the election in 2007. It contains some 138 recommendations for long-term reform of the tax and transfer system ...
After becoming the object of several infringement procedures conducted by the European Commission, Spain has been forced to amend several non-resident income tax provisions to ensure those provisions comply with the principles enshrined in the Treaty on the Functioning of the European Union ...
The Texas franchise tax (also known as the “margin tax”) is so expansive that it can apply to private trusts administered in Texas. Every taxable entity is subject to the franchise tax, and the term “taxable entity” generally includes trusts, partnerships, limited liability companies, and corporations. If the franchise tax applies to a trust, the amount of franchise tax will typically be 0.7% of the trust's federal gross income that is apportioned to Texas (i.e ...
As we navigate the waters of these tough economic times, appraisal districts faced with massive city, school and county revenue losses caused by declining property values will most likely try to stem the tide by not voluntarily lowering taxpayers’ 2010 property values to their fair market values ...
Dear Sirs, We would like to present you a brief overview of tax legislation updates concerning transfer pricing and VAT on services upon importation of goods into the territory of the Russian Federation. Draft law On Transfer Pricing We would like to pay your attention to the fact that draft law “On transfer pricing” was accepted by the State Duma in the 1st reading ...
Historically, a significant number of states had a general policy of respecting the form of a transaction chosen by a taxpayer and applied their sales tax laws based on that form of transaction ...
The Australian Taxation Office's unsuccessful attempt to freeze the bank accounts of the private equity firm Texas Pacific Group has highlighted the ATO's new focus on private equity activities in Australia. The attempted freeze followed the stock market float of the Myer Group, as the ATO sought a reported tax bill of $A452 million from TPG ...
The Foreign Investment Review Board (Board), being the Australian government body that examines proposals for foreign investment in Australia, recently announced that the monetary thresholds set for the purposes of compulsory notification to the Board of a proposed acquisition will be revised to: AUD231 million, for private business investment (up from AUD219 million); and AUD1004 million, for US investors under the Australia-US Free Trade Agreement (up from AUD953 million) ...
The Russian Federation, the Kazakhstan Republic and the Belarus Republic (hereinafter also referred to as the “Member States”) have formed Customs Union in accordance with the Treaty on Creation of Unified Customs Territory and Formation of Customs Union (Dushanbe, October 6, 2007) ...
Following the recent actions taken by the Australian Taxation Office to freeze the bank accounts of the private equity firm TPG, the Commissioner of Taxation has released two draft Taxation Determinations (TDs): TD 2009/D17 Treaty Shopping - Can Part IVA of the Income Tax Assessment Act 1936 apply to arrangements designed to alter the intended effect of Australia's International Tax Agreements network?; and TD 200
In light of the ineffectiveness of tax litigation and the increased mistrust of taxpayers in relation to tax decisions, with the decision-makers very often hiding behind mere decisions of form, it is imperative that we weigh up alternative methods for resolving tax disputes, such as mediation, conciliation, and tax arbitration itself, in order to deal with disputes accumulated and arising out of relations between the State and the taxpayer, thus reversing the fe
We would like to present you an overview of the most valuable changes in Tax legislation effective since January 1, 2010. Also we would like to point out the recently adopted Decision of the Presidium of the Supreme Arbitrazh Court of the Russian Federation significant from the tax standpoint ...
The transfer tax situation for 2010 could hardly be more confusing. A last-ditch effort in the Senate to extend the 2009 rates and exemptions was blocked by Senators who support repeal or higher exemptions and lower rates. Supporters of continuing the 2009 rules ($1 million gift tax exemption, $3 ...
The Government of the Republic of Indonesia has entered into over 60 agreements on avoidance of double taxation with other countries. These agreements normally state the scope and the parties who are entitled to avoidance of double taxation benefit. In practice, some parties may abuse the avoidance of double taxation by structuring a transaction in a certain way ...
THE CONFIDENTIALITY AGREEMENT, CAN YOU LIVE WITHOUT IT?Patrice André [email protected] are advising a client who is selling his business. The parties have already signed a letter of intent that provides for a due diligence review to be conducted in respect of your client’s business ...
We would like to draw your attention to the upcoming valuable updates in Tax legislation. Below we have placed a short overview of the hottest issues already occurred in Russian tax environment and some to be introduced in the nearest future. Respectively, these incentives are proposed either to overcome consequences of the financial crisis, or to realize the next step of the long-term policy of stabilization and modernization of the Russian tax system ...
At the same time, the effective rate of tax on dividends for high earners will rise from 25% to 36%. No changes are currently proposed to the rate of capital gains tax which means it will remain at 18%. However, both main parties have now admitted that further tax increases are likely. With the gap between income tax and capital gains being a massive 32%, it seems unlikely that the current generous rate of capital gains tax will remain in place ...
When a company goes into administration, a statutory moratorium takes effect to help the administrators achieve the objectives of the administration. Amongst other things this means that no legal process can be started or continued against the company without the consent of the administrators or the court ...
Several countries have already introduced the concept of “temporary non-residents” into their tax orders, thus enabling them to lay down special rules regarding the taxation of income received by those who are habitually resident in these countries, but take up residence in another country for a certain period – which as a rule does not exceed 5 years and is very often a result of secondment - and subsequently return to their former country of residence ...
The Letter of Intent: Beyond the Words, the Intent and Conduct of the PartiesModifying a Trust Deed: It Is Not So Simple!Maximizing the Use of Post-merger Losses THE LETTER OF INTENT: BEYOND THE WORDS, THE INTENT AND CONDUCT OF THE PARTIESPatrice [email protected] letter of intent often constitutes the first document that the parties sign in view of entering into a Business transaction ...
According to The Federal law as of July 24, 2009 N 212-FZ “On Insurance Contributions to the Pension Fund of the Russian Federation, Social Security Fund of the Russian Federation, Federal Medical Insurance Fund of the Russian Federation and Territorial Medical Insurance Funds” that has been passed by the State Duma, the Unified social tax (UST) shall be replaced from the year 2010 with insurance contributions to particular types of social security to be paid to four separate non-budge
Following our tax information regarding “New Tax Forms on Interest and Royalties” and “International Double Taxation in Portugal” of the 9th of March and the 8th of July 2009, respectively, were on July the 20th, released the new forms of models 21, 22, 23 and 24 RFI for implementation of the treaty to avoid the double taxation between Portugal and Spain, hereby attached and that are available at the Portal das Finanças ...
In January 2010, the decree-law that enacts the Accounting Standardisation System and repeals the Official Chart of Accounts (POC) will enter into force. This legislation was passed as part of a reform that is intended to be structural in nature and apply horizontally across the national accounting system ...
