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Documents on Taxation, Banking & Financial Services
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|Ignoring IRS Notice of Deficiency May Leave Taxpayer With No Recourse for Contesting Tax Liability|
Jill Misener, David J. Moise; Withers Bergman LLP;
November 28, 2014, previously published on November 20, 2014The US Tax Court recently held in Onyango v. Comm’r 142 T.C. 24 (2014) that a taxpayer could not contest a tax liability prior to making payment where the Internal Revenue Service (IRS) issued a valid Notice of Deficiency and the taxpayer failed to take advantage of previous opportunities to...
|New IRS Streamlined Filing Procedures Expands Eligibility to Us Residents and Foreign Residents|
Shannon Smith Retzke; Withers Bergman LLP;
November 28, 2014, previously published on November 20, 2014For the first time, the Internal Revenue Service (IRS) streamlined filing procedures are available to US resident taxpayers who have unreported foreign income or financial accounts. The new streamlined procedures also eliminate the risk assessment process associated with the old streamlined...
|Eurasian Economic Union|
Victoria Simonova; Dentons Canada LLP;
November 17, 2014, previously published on October 8, 2014On 29 May 2014, the presidents of Kazakhstan, Russia and Belarus signed an agreement (the "Treaty") in Astana on the Eurasian Economic Union (the "EaEU" or the "Union"). The Treaty will enter force on 1 January 2015. According to the Treaty, the Union is an...
|New Provisions Concerning Thin Capitalization in Poland|
BSJP Brockhuis Jurczak Prusak Sp.k.;
October 31, 2014On the 1st January 2015 the provisions regarding tax deduction of the interest paid for the loans provided by the related companies (thin capitalization) are about to change.
|Canadian Back-to-Back Loan Proposals|
Nigel P.J. Johnston, Gabrielle M.R. Richards; McCarthy Tétrault LLP;
October 22, 2014, previously published on October 15, 2014The 2014 federal budget included measures (Budget Measures) intended to eliminate the use of back-to-back loans to avoid the thin capitalization rules and/or withholding tax on interest paid to non-arm’s length non-residents so as to protect the Canadian tax base from erosion by limiting the...
|VAT Groups: Potential VAT Costs for Financial Groups as ECJ Recognises Intra-Entity Supplies between US Head Office and VAT-Grouped Branch|
Sullivan Cromwell LLP;
October 19, 2014, previously published on October 10, 2014The European Court of Justice has decided that IT services provided by Skandia America Corporation to its Swedish branch should be recognised for VAT purposes because the Swedish branch was part of a VAT group.
|Repeal of the Interest-Withholding Tax on Certain Cross-Border Loans|
October 16, 2014, previously published on October 2014As a rule, if a nonresident lender grants a loan to an Italian resident borrower, the interest paid on the loan is subject to a 26 percent withholding tax in Italy unless the lender is eligible for the exemption under the Italian laws that implemented the EU Interest and Royalties Directive. The...
|Tax Evasion: Number of Amended Tax Returns Has Doubled|
Andreas P. Demetriades; Andreas P. Demetriades & Associates- Advocates,Legal and Tax Consultants - Law Firm;
October 8, 2014Cyprus: The three most popular types of International Business Companies (IBCs) operating through Cyprus: Financing, Holding and Trading Companies.
|Foreign Asset Disclosure, Financial Reporting and Tax Planning in a Complex World|
Alison V. Lennarz; Kaufman & Canoles A Professional Corporation;
September 11, 2014Globalization, and the interwoven economies of countries around the world that result from it, is only gaining momentum. Increasingly sophisticated communications and transportation technologies and services, mass migration and the movement of peoples, a level of economic activity that has outgrown...
|Non-Dischargeable Tax Debt Not Special Class of Unsecured Creditors|
Scott St. Amand, J. Ellsworth Summers; Rogers Towers, P.A.;
August 28, 2014, previously published on August 26, 2014In numerous previous posts, we have noted that the purpose of the Bankruptcy Code is to help the “honest but unfortunate debtor.” Like gerrymandering, certain “creative” debtors have attempted to classify their non-dischargeable debt as a separate, special class of unsecured...