Brazil – Social Security Tax on Exports to Trading Companies
The tax department has issued guidance clarifying that revenues from the sale of products to trading companies for the purpose of export are subject to social security taxation. Normative Instruction 1436 (IN 1436) released on 9 January 2014 was
See MoreColombia: Thin capitalization provision
Under the Decree 3027 of 27 December 2013, the thin capitalization provisions interest is fully deductible up to a debt to equity ratio of 3:1. This applies to domestic and foreign loans from related or unrelated
See MorePGA Highlights: January 2014
In United States, The following events have been taken place under the several PGA during the month of January 2014. Agencies Summary Link Federal Register Importation of Fresh Bananas From the Philippines Into Hawaii and U.S. Territories: A
See MoreUnited States: ADD/CVD Roundup for January 2014
Following table shows the Federal Register notices related to ADD/CVD cases for January 2014 in United States. Country Product Investigations Case Number Links Brazil Polyethylene Terephthalate Film, Sheet, and Strip Final Results
See MoreUS: IRS begins online transcript service
United States taxpayers now have the option to download their tax transcripts online from the “Get Transcript” service of the Internal Revenue Service (IRS). Through the Get Transcript service, taxpayers can obtain an official copy of their past
See MoreUS: Congressional call to maintain charitable tax deduction
Two members of the Senate Finance Committee led a bipartisan group of more than 30 senators in a recent letter to its Chairman Max Baucus and Ranking Member Orrin Hatch underscoring the importance of maintaining the charitable tax deduction in any
See MorePeru: Changes to “frequent importers” regime
On 11 January 2014, the tax administration of Peru issued a resolution establishing changes to the “frequent importers” regime (Relación de Importadores Frecuentes). Resolución No. 00002-2014-SUNAT/300000 offers a list of the importers
See MoreItaly: FATCA intergovernmental agreement signed with United States
Representatives of the governments of Italy and the United States signed an intergovernmental agreement to implement the provisions of U.S. law known as “FATCA” (Foreign Account Tax Compliance Act). According to a Ministry of Economy and Finance
See MoreBrazil: Withholding tax thresholds for Employee Profit-Sharing Plans Increased
The employee profit-sharing plan (participação nos lucros ou resultados, PLR) related tax withholding thresholds in Brazil have recently been modified. This will be applicable from 1 January 2014. For the taxable year 2014, the tax withholding
See MoreArgentina: Highest tax to GDP in Latin America is reported
According to the Economic Commission for Latin America and the Caribbean (ECLAC), tax revenue in Argentina is the the largest and fastest growing among this region. The latest tax revenue-to-GDP data of Argentina was 37.3 percent, which put the
See MoreCanada: Lower Tax Rates demanded for Small Businesses
The Canadian Federation of Independent Businesses (CFIB), in presenting budget requests to the Finance Minister, has recommended a gradual reduction of the small business tax rate from 11% to 9%. CFIB feels that these changes will help the small
See MoreUnited States: Technology Industry Lobbies for expanded Research Tax Credit
TechAmerica, a technology industry group, has asked that the tax credit for research and development (R&D) should become permanent, and be refundable for small start-ups. The R&D credit expired on 31 December 2013; it had survived as a
See MoreEcuador ratifies DTA Protocol signed with China
Ecuador ratified the Protocol to the DTA with China through Decree no. 208 on 13 January
See MoreArgentina: White List Available
The Argentinian tax administration (AFIP) issued Resolution No 3576 on 7 January 2014, which makes public the white list of cooperative jurisdictions, effective from 1 January, 2014. Countries not in the white list are to be treated as “not
See MoreArgentina: Court Decision on withholding tax on commissions paid
Argentina’s Supreme Court has ruled that commissions paid by Argentine borrowers are Argentine-source business income and subject to withholding tax. The case was Hidroeléctrica El Chocón SA c/ DGI where Hidroeléctrica El Chocón (HEC), paid
See MoreArgentina: New income tax on specific exports
Argentina issued Resolución General N°3577/2013 on 7 January 2014 that establishes a new income tax (Impuesto a las Ganancias) on transactions where goods are exported to a foreign jurisdiction other than the jurisdiction billed for the
See MoreUnited States: trust residency regulations
The US Treasury Department and the Internal Revenue Service (IRS) have requested comments on the existing final regulations (TD 8813) that provide guidance on determining the residence of a trust for US tax under section 7701 of the US Internal
See MoreCanada: New Anti-Avoidance Program
The Canada Revenue Agency (CRA) has announced the Offshore Tax Informant Program (OFTP) that offers financial rewards for information that helps address major international tax non-compliance. Rewards will be paid to individuals for evidence with
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