US and Hong Kong- tax information exchange agreement (TIEA)
On April 25 2014 Hong Kong gazetted the tax information exchange agreement (TIEA) with the United States. The agreement will take effect after the relevant legislative procedures have been completed. The OECD has been encouraging the conclusion of
See MoreMexico – Transfer pricing implications of pro-rata expense decision
A recent decision from Mexico’s Supreme Court of Justice declared a provision of the tax law to be unconstitutional. The provision related to pro-rata expenses incurred abroad relating to natural or legal persons that are not Mexican taxpayers.
See MoreSingaporean DTA with Barbados in Force
The double taxation agreement (DTA) concluded between Singapore and Barbados came into force on April 25, 2014. The agreement which was originally signed in July 2013 provides for a nil withholding tax rate on dividends, a 12 percent withholding
See MoreMexico: Appeal procedures for certain challenges to tax reform
Mexico’s Supreme Court of Justice (Suprema Corte de Justicia de la Nación) has postponed the hearing of appeals in amparo actions, these being legal actions that challenge the constitutionality of some measures included in the 2014 tax reform.
See MoreColombia: Percentage of deemed interest on loans between companies and their partners or shareholders
The Colombian government issued decree 629 concerning income tax on 26 March 2014. This decree lays down that the deemed interest on loans between companies and their partners is to be set at 4.07% for year
See MoreColombia: issues regulations on thin capitalization provisions
The Colombian government issued Decree 627 on 26 March 2014. This Decree regulates the thin capitalization rules (article 118-1 of the Tax Code) that were brought in as part of the recent tax reforms and takes effect from the date of publication.
See MoreFATCA agreement between Australia and United States signed
Australia and the United States signed an agreement relating to US Foreign Account Tax Compliance Act (FATCA) on 28 April 2014. These intergovernmental agreements are being concluded by the US in connection with the implementation of the FATCA in
See MoreUS : Persons holding PFIC stock through tax-exempt organizations or accounts will be exempt from Form 8621 filing requirements
In the US the definition of a shareholder for the purpose of the Section 1291 regulations has been amended by Notice 2014-28. Under this section a special tax and interest charge is levied on a US person has shares in a passive foreign investment
See MoreUS: ATR finds that Obama has proposed 442 tax hikes
The organization known as Americans for Tax Reform (ATR) has calculated that since 2009 President Obama has proposed 442 tax increases. This figure results from a survey of the budgets for the fiscal years 2010 to 2015. In addition to these tax
See MoreUS – More taxpayers e-filing from home computers
An internal report issued by the Treasury Inspector General for Tax Administration (TIGTA) indicates that more US taxpayers are using e-filing to submit their tax returns and that more tax refunds are being issued. By 7 March 2014 more than 90
See MoreUS – IRS issues 2014 foreign housing tax deduction limits
In the US the Internal Revenue Service (IRS) has issued Notice 2014-29. The Notice sets out the inflation-adjusted limitations in respect of foreign housing expenses for tax year 2014. The figures included in the Notice show that Hong Kong, Moscow,
See MoreUS: GAO Reports that Large Partnerships are Avoiding the IRS Net
In a preliminary report from the United States Government Accountability Office (GAO) it is shown that the IRS is currently conducting a tax audit in respect of only around one percent of the largest partnerships in the US. The GAO report suggests
See MoreUS: Budget proposals for 2015 have implications on inbound investors
In March 2014, the Obama Administration (the Administration) released its fiscal year 2015 Budget proposals (the Budget). In addition to the transfer pricing rules the earnings stripping rules also apply to transactions with foreign related parties
See MoreTreaty between Argentina and Mexico under negotiations
An initial round of negotiations for a double tax treaty between Argentina and Mexico is to take place from 21 to 25 April
See MoreUS: Tax Foundation Considers Future of US Tax Breaks
The Tax Foundation (TF) in the US considers that a number of corporate and individual tax breaks should be recognized as fulfilling a beneficial purpose, even though the US government is currently considering their abolition. Many of the tax breaks
See MoreUS: IRS Gives Bonuses to Tax-Delinquent Employees
In the US the Treasury Inspector General for Tax Administration (TIGTA) provides independent oversight of the activities of the Internal Revenue Service (IRS). TIGTA aims to ensure economy and efficiency of administration within the IRS and is
See MoreMexican tax reform of 2014 imposes deadlines for Maquiladora companies
The Mexican tax reform of 2014 has introduced a number of important changes for maquiladora enterprises. The changes apply to companies that are operating under the requirements of the Decree for the Promotion of the Manufacturing, Maquiladora and
See MoreFATCA agreement between Belgium and the US
An intergovernmental agreement (IGA) between Belgium and the US is to be signed on 23 April 2014 in relation to the implementation of the US Foreign Account Tax Compliance Act (FATCA). The IGA requires the tax administrations of the two countries to
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