Switzerland and United States FATCA agreement enters into force
The Federal Council decided, on June 6, 2014, that the FATCA agreement between Switzerland and the United States came into force on June 2, 2014. This agreement was approved by the parliament in September 2013. The FATCA execution in Switzerland is
See MoreBrazil: Tax exemption from Foreign Loans
The Finance Minister of Brazil declared that the government has announced to cut some tax on foreign loans and from the Tax on Financial Transactions (IOF) on 4 June of 2014 and introduced a new Decree No. 8263The 6% IOF will no longer applicable
See MoreCanada – Tax deduction for SMEs from Quebec 2014-15 budget
The Minister of Finance and the Economy of Quebec has delivered the province’s 2014 budget on June 4, 2014. The budget contains a declaration for a deduction of income tax rate for manufacturing small and medium-size enterprises (SMEs) in Quebec,
See MoreCanada – Newfoundland Budget substantively enacted in 2014
Newfoundland Bill 13 containing tax changes has declared as Newfoundland Budget in the 2014. As Newfoundland has a majority government, the bill is allowed substantively enacted for motives of IFRS and ASPE as of May 26, 2014. Bill 13 contains
See MoreCanada: Searching for Block Expanded Expat Voting Rights
The Government desires to appeal a recent court judgment stating that expats who have been outside the country for more than five years should be approved to vote and it was said by Canada's Minister for Democratic Reform. The shortcomings were
See MoreVenezuela – Regulations regarding commercial property leases
A new legislative decree has published in late May 2014 including changes to the rules regarding commercial property leases in Venezuela. As determined by the tax authorities, the decree also establishes the invoice provided by the landlord to the
See MoreMexico: Presented Further Maquila VAT Refunds
The finance minister of Mexico has introduced a 16% VAT on imports through maquila and it will start from 1 July 2014 and government expected it will providing quick VAT refund on import in the Mexico through a 100% tax credit. The government
See MoreCanada: New guidance regarding contemporaneous documentation
The CRA’s updated Transfer Pricing Memorandum (TPM-05R) clarifies the CRA’s process for requesting contemporaneous documentation and includes specifically four new sections, such as method of delivery, three-month delivery, documents provided to
See MoreIRS warns filing deadlines for US Expats
US citizens and resident living overseas who are eligible for an automatic two-month extension after the regular April 15 tax filing date must file their 2013 federal income tax returns by June 16. Since 15 June is Sunday this year taxpayers get one
See MoreTurkey enlisted as having FATCA in effect
Turkey has reached an intergovernmental agreement (IGA) with the United States to execute the Foreign Account Tax Compliance Act (FATCA), and has agreed to be listed on the website of the US Treasury Department as a jurisdiction that is supported as
See MoreMexico-UAE: Income Tax Treaty ratified by Mexico
Mexico has ratified the income tax treaty between Mexico and the United Arab Emirates on May 26, 2014 which was signed on November 20, 2012 by way of Presidential
See MoreCanada -Australia ITT regarding income of employee on a short-term secondment
The Australian Taxation Office has published Interpretative Decision ATO ID 2014/20 on May 30, 2014 regarding the income of a non-resident individual engaged by a resident employer resident in Canada is taxable in Australia despite that the employee
See MoreCanada follows suit with US and excludes references to OECD in TP request
Canada has adopted similar position to the US and has excluded references to the OECD’s three-tier documentation in favour of its own country specific transfer pricing (TP) documentation. The Canada Revenue Agency (CRA) has reviewed its TP
See MoreUS: Poor Policy for IRS Tax Enforcement-TIGTA
The Treasury Inspector General for Tax Administration (TIGTA) recently released a report on actions taken by the United States Internal Revenue to collect individual Federal income, Social Security, and Medicare taxes unpaid by businesses were not
See MoreVenezuela – Palestine: DTA sign
Venezuela and Palestine signed a double taxation agreement (DTA) on May 17, 2014. No further details of the agreement are currently
See MoreUS: Taxpayers Giving Up US Passports As FATCA Approaches
The FATCA may be causing some taxpayers to give up their US citizenship. According to statistics issued by the US Treasury Department statistics and included in the Federal Register, more than one thousand United States taxpayers relinquished their
See MoreUS: Study Moves to Curb State Corporate Tax Incentives
The Council on Foreign Relations (CFR) in the US has recently published a memorandum that looks at the tax relief and subsidies the US federal and state governments grant every year as an incentive to attract business investment. The memorandum
See MoreUS: IRS Releases Transfer Pricing Audit Roadmap
On 14 February 2014 a Transfer Pricing Audit Roadmap was issued by the Large Business and International (LB&I) division of the IRS. This sets out the procedures in relation to the conduct of a transfer pricing audit and the timeline to follow.
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