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Articles on taxation
Articles on taxation
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 | Congressional Tax Proposals May Significantly Impact the Global Financial System
November 6, 2009, previously published on November 2009 On October 27, 2009, the Chairmen of the House Ways and Means and the Senate Finance Committees introduced identical legislation ostensibly aimed at offshore tax evasion. The bill is titled the "Foreign Account Tax Compliance Act of 2009" (the Act). The Act has already earned the nickname... |
 | Thai Revenue Department Proposes End to Non Juristic Bodies of Persons
November 6, 2009, previously published on November 4, 2009 The Thai Revenue Department is advocating for non-juristic bodies of persons to be stripped of their status under the Revenue Code in order to prevent abuse and tax evasion. |
| Section 162(m) Transition Relief May Be Expiring for 2010 Performance-Based Compensation
November 6, 2009, previously published on October 29, 2009 In 2008, the IRS issued a ruling limiting the deductibility of certain incentive compensation under Section 162(m) of the Internal Revenue Code. |
| Foreign Account Tax Compliance Act of 2009: Information Reporting for US Client Accounts at Non-US Financial Institutions
November 6, 2009, previously published on November 5, 2009 On October 27, 2009, Senators Baucus and Kerry, together with Representatives Rangel and Neal, introduced the Foreign Account Tax Compliance Act of 2009 (the "Act"). The bill is the product of consultation between Congress and the US Treasury Department (Treasury) and is intended to curb... |
| Customs Proposes Regulations to Allow Offsets of Duty Overpayments in Audits and Disclosures
November 6, 2009, previously published on November 5, 2009 U.S. Customs and Border Protection (CBP) recently announced proposed amendments to its regulations to allow for sampling and offsetting of underpayments with overpayments in CBP audits and prior disclosures. 74 Fed. Reg. 53,964 (October 21, 2009). For years CBP and importers have used sampling in... |
| Recently Introduced Tax Legislation of Interest to Funds and Fund Managers
Brian W. Kniesly, David I. Shapiro; Fried, Frank, Harris, Shriver & Jacobson LLP; November 5, 2009, previously published on October 30, 2009 Earlier this week, the "Foreign Account Tax Compliance Act of 2009" (the "bill") was introduced in the Senate and the House. The bill is another effort aimed at curbing tax evasion through use of foreign financial accounts and investments by United States persons, although many... |
| 2010 Conversion of a Traditional IRA to a Roth IRA
Haynes and Boone, LLP; November 5, 2009, previously published on November 03, 2009 Currently, only taxpayers with modified adjusted gross income of $100,000 or less (who are not married filing separately) may convert a traditional IRA to a Roth IRA. Beginning January 1, 2010, the $100,000 limitation will be eliminated, and all taxpayers (including married taxpayers filing a... |
| The Community Infrastructure Levy
Richard M. Adams, John F. Mitchell; Jones Day; November 5, 2009, previously published on October 2009 On 23 October 2009 the Department of Communities and Local Government's consultation exercise in respect of the Community Infrastructure Levy ("CIL") closed. |
| UCP 600: Confirming Banks and Nominated Banks
Edwin Borrini, David M. Fricker, Amy Kho; Jones Day; November 5, 2009, previously published on October 2009 Fortis Bank S.A./N.V. and Stemcor UK Limited v Indian Overseas Bank is one of the first cases to consider the language of the current edition of the Uniform Customs and Practice for Documentary Credits ("UCP 600") relating to the right of reimbursement owed by an Issuing Bank to a... |
| Employers Must Act Quickly to Take Advantage of Limited Grace Period for Correcting Certain Operational Violations under Code Section 409A
Rebecca C. Davenport, Maureen J. Gorman; Mayer Brown LLP; November 5, 2009, previously published on November 2, 2009 Employers must act by the end of 2009 if they want to take advantage of transition relief provided by Notice 2008-113 (the Notice) for certain types of operational violations of the rules under Internal Revenue Code Section 409A that occurred prior to 2008. |
