US CEOs United On Need for Tax Reform
An annual survey of the views of US Chief Executive Offices (CEOs) reveals that more than 80 percent of those asked are of the opinion that the international tax system must be restructured and around two thirds of those asked want a more
See MoreMexico Provides Oil Tax Reform Framework
A bill recently introduced by the government contains more detail of the new tax regime in respect of oil companies. This aims to encourage further exploration with the aim of increasing oil production in the future. The state oil and gas company
See MoreIsrael and US Reach FATCA Agreement
Israel and the US have agreed on the wording of an intergovernmental agreement (IGA) that will enable the provisions of the US Foreign Account Tax Compliance Act (FATCA) to be carried out in Israel. The FATCA takes effect from 1 July 2014 and from
See MoreCanada – Tax proposals in Ontario’s 2014 budget
Ontario’s 2014 budget proposals were announced on 1 May 2014. The measures proposed in the budget include a personal tax increase for individuals earning above CAD150,000; the phasing out of the small business deduction given to some larger
See MoreCanada – Foreign affiliate anti-avoidance rule and tax efficient financing
The Federal Court of Appeal has upheld the verdict of a lower Court that the foreign affiliate anti-avoidance rule does not lead to the loss of the tax deduction in respect of exempt surplus dividends received from a US affiliate using a tax
See MoreUnited States: ADD/CVD Roundup for April 2014
Following table shows the Federal Register notices related to ADD/CVD cases for April 2014 in United States. Country Product Investigations Case Number Links Brazil Certain Frozen Warmwater Shrimp Initiation of Antidumping Duty
See MorePGA Highlights: April 2014
In United States, The following events have been taken place under the several PGA during the month of April 2014. Agencies Summary Link Federal Register Labeling of Pesticide Products and Devices for Export: This action will allow placement
See MoreUS: Notice 2014-32 announces amendments to recently finalized Section 367(b) regulations applying to certain cross-border triangular reorganizations
The US Treasury Department and US Internal Revenue Service have issued Notice 2014-32 revising the final regulations on certain cross-border triangular reorganizations. The Notice applies where the reorganization involves one or more foreign
See MoreSweden – Intergovernmental agreement under FATCA
The US and Sweden have reached substantial agreement on the content of an intergovernmental agreement (IGA) in relation to the US FATCA regulations. The aim of such agreements is to allow the relevant information required by FATCA to be exchange
See MoreMexico – VAT certification by maquiladoras
The maquiladora regime provides some favorable tax provisions but caution is needed with administrative procedures in respect of VAT. As a result of changes introduced in the 2014 tax reform maquiladoras must take certain actions to ensure they are
See MoreUS 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
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