Search Results (1477)
Documents on Taxation, Banking & Financial Services
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|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...
|Chile and the United States Sign the Inter-Governmental Agreement ("IGA") Within the Scope of the Foreign Account Tax Compliance Act ("FATCA")|
Diego Peralta, Jessica Power, Elena Yubero; Carey;
August 15, 2014FATCA is a United States Act that requires US persons, including individuals who live outside the United States, to report their financial accounts held outside of the US, and requires foreign financial institutions ("FFIs") to report information regarding their US clients to the US...
|New Tax Rules for Loans Taken Out By UK Resident Non-Domiciliaries|
Withers Bergman LLP/Withers LLP;
August 6, 2014, previously published on August 5, 2014With effect from 4 August 2014, HMRC have changed, without notice, their stated position with respect to the treatment of commercial loans to UK resident and non-domiciled individuals. Action is required if individuals wish to avoid paying additional tax as a result of their existing arrangements.
|Congress Scrutinizes Hedge Funds’ Use of Financial Derivatives|
Bruce M. Bettigole, Thomas A. Cullinan, Yasho Lahiri, William R. Pauls, W. Scott Sorrels; Sutherland Asbill & Brennan LLP;
July 30, 2014, previously published on July 25, 2014This week the Senate Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs (Subcommittee), in conjunction with the Subcommittee’s hearing on July 22, 2014, released a report on hedge funds’ use of financial derivatives considered abusive. In...
|Excess Lines Association of New York Advises on Foreign Account Tax Compliance Act (FATCA) Compliance|
Colodny Fass Talenfeld Karlinsky Abate Webb P.A.;
July 22, 2014, previously published on July 18, 2014In Bulletin No. 2014-15 issued yesterday, July 17, 2014, the Excess Lines Association of New York ("ELANY") responded to questions it has received to date about the implementation of the Foreign Account Tax Compliance Act ("FATCA"), which is scheduled to go into effect under its...