Canadian non-resident permitted to carry-forward of non-capital losses
The Canadian Tax Court issued a decision regarding a case entitled Hatt v. The Queen (2015 TCC 207) on 19th August 2015. The issue was whether the taxpayer was entitled to deduct a non-capital loss from employment in Canada in the 2010 tax
See MoreCanada: CRA issues 2014-15 APA program report
The Canada Revenue Agency (CRA) has published a report on 17th August 2015 regarding Advance Pricing Arrangement (APA) program for the period from 1st April 2014 to 31st March 2015. This gives an overview of the systems of APA program containing
See MoreBulgaria-US: FATCA agreement entered into force
In accordance with a declaration made in the Bulgarian State Gazette on 26th June 2015, the FATCA Model 1B Agreement (2014) between Bulgaria and United States has entered into force on 30th June 2015. An intergovernmental agreement (IGA) for the
See MoreCanada: CRA releases annual MAP report
The Canada Revenue Agency (CRA) has published its 12th annual report regarding its Mutual Agreement Procedure (MAP) programme. The report gives the objective, history, and present events of the MAP programme for the period from 1st April 2014 to
See MoreColombia- Tax haven transactions subject to transfer pricing regime
The National Tax Authority of Colombia published Ruling 20776 of 2015 according to which transactions carried out with tax haven jurisdictions in tax year 2014 are subject to the transfer pricing regime. According to article 260-7 of the Tax Code
See MoreTreaty between Argentina and Chile – Chilean guidelines issued on treatment of shipping companies following termination of treaty
The tax authority of Chile issued Order No. 1757(the Order) on 6 July 2015 according to which Chilean shipping companies are obliged to pay income tax under the provisions of article 59 of the Income Tax Law whenever operating with Argentina. Also
See MoreArgentina-Deadline for issuance of VAT electronic invoices and records
The tax administration of Argentina published General Resolution No. 3,793 in the Official Gazette on 10 August 2015. According to the resolution 31 March 2016 is the deadline for the electronic issuance and storage of VAT receipts by taxpayers
See MoreBrazil: Presents new proposal on taxation for financial firms and interest on net equity
Brazilian Senator presented a report on the analysis of Provisional Measure 675 (MP 675) regarding new social contribution on net profits (CSLL) rate and elimination of interest on net equity on 12 August 2015. MP 675: Tax rate (CSLL) increased
See MoreChile: IRS issues guidelines regarding anti-avoidance rules
The Inland Revenue Service (IRS) in Chile has issued total 7 circulars including Circulars 65 and 68 on 23rd July 2015 for giving directions won the anti-avoidance rules enacted as part of Law No. 20780. The circulars contain limitations on the
See MoreUS: IRS Issued New Revenue Procedures on Competent Authority and Advance Pricing Agreement
The IRS has issued two revenue procedures on August 12, 2015 with details guidance to request assistance from the US competent authority under income tax treaties and to obtain an advance pricing agreement (APA) program. The proposed version of
See MoreEcuador-new regulations on transfer pricing documentation requirements
Recently Ecuador’s Internal Revenue Service (IRS) has issued regulations giving outlines to new transfer pricing documentation requirements. The new regulations require taxpayers to include substantial information on the economic substance of
See MoreChile: Bill to amend the tax reform of 2014
The Finance Ministry has declared that the Government submitted a bill on 10th August 2015 to amend the tax reform of 2014. The main features of the bill will be as follows: The combined income tax regime with income attribution would be
See MoreCanada-India: Social Security Agreement entered into force
A Social Security Agreement between Canada and India enter into force from 1st August 2015 that was signed on 6th November 2012. It also effects from the same date of entry into
See MoreUS: IRS Issues Notice 2015-54 Limiting Ability to Transfer Property to a Partnership Tax Free
The IRS and Treasury published Notice 2015-54 on August 6, 2015 modifying the rules applicable to the contribution of built-in gain property to a partnership. Under the Notice, a U.S. transferor is required to recognize any built-in gain on the
See MoreUS Treasury to develop regulations implementing CbC reporting requirement
US Treasury announced on 31 July 2015 that the US government intends to develop regulations implementing the OECD/G20 base erosion and profit shifting (BEPS) action plan guidance on country-by-country (CbC) reporting by multinational
See MoreChile: Taxation of foreign investors and change of residence
The tax authority in Chile has issued Circular No. 1985 in relation to the taxation of Chilean-sourced investment income of foreign investors. The Circular explains the responsibility of the foreign investor to advise any change of residence to
See MoreFATCA Agreement Signed between United States and Slovakia
Slovakia and the United States have signed a Foreign Account Tax Compliance Act (FATCA) agreement on 31 July 2015. This is a Model 1 Agreement. Under this reciprocal agreement, Slovakia will report the information required under FATCA about U.S.
See MoreUnited States: ADD/CVD Roundup for July 2015
Following table shows the Federal Register notices related to ADD/CVD cases for July 2015 in United States. Country Product Investigations Case Number Details Mexico Carbon and Certain Alloy Steel Wire Rod Notice of Court Decision Not in
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