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WEB2 days ago · Africa. This week in tax: Ireland progresses with new participation exemption. Ralph Cunningham, August 30, 2024. This month in indirect tax: UK parties say no to higher VAT. Ralph Cunningham, June 05, 2024. This month in indirect tax: Brazil moves closer to widespread reform. Ralph Cunningham, May 08, 2024.
Understanding the beneficial ownership v. beneficial holding …
WEBSep 14, 2021 · The concept of ‘beneficial ownership’ is found under the international tax treaties. The tax treaties are negotiated based on the model tax conventions and these conventions inter alia provide explanations as to the intent and purpose behind terms appearing therein. The phrase ‘beneficial owner’ appears in both the OECD Model Tax Convention and the UN Model Tax Convention in the ...
The long expected Brazilian tax reform – objectives, challenges and ...
WEBMar 30, 2020 · The Brazilian government and the Congress began 2020 by reiterating that reforming the tax system is one of the main priorities and that the initial objective is to consolidate the different propositions into a single project, which would follow the legislative process within the House of Representatives and the Senate.
Conferences | International Tax Review - ITR
WEBApr 25, 2024 · ITR produces 8 high-level conferences and summits a year which attract over 1,000 attendees. For more information, contact: Jamil Ahad, Commercial Director. [email protected]. +44 (0) 207 779 8767. Jamil heads up …
IP transfers: Tax and accounting considerations
WEBDec 17, 2012 · Royalties paid in exchange for the right to use or exploit IP outside of the US are typically foreign-source income – IRC §862(a)(4). In contrast, the gain from the sale of IP – patents, copyrights, secret processes or formulas, goodwill, trademark, trade brand, franchise, or other like property – is generally sourced under IRC §865 according to the residence of the seller.
Final FFI agreement offers transition for due diligence
WEBJan 8, 2014 · The final FFI [foreign financial institution] agreement, which was published on December 26, includes a provision for a two-year transition period during which a reporting Model 2 FFI may elect to apply the due diligence procedures in the FFI agreement in place of those in Annex I of an applicable Model 2 IGA [intergovernmental agreement]. This election is made by the reporting Model 2 FFI and ...
A brave new world in tax transparency: CRS in China, Hong Kong …
WEBNovember 28, 2017. Increasing cross-border business and investment has made the holding of assets overseas through offshore accounts increasingly common. This has become a new tax battleground for businesses and governments. Charles Kinsley, Henry Wong, and Eva Chow look at the latest developments regarding these efforts in China, Hong Kong and ...
Understanding FIRPTA: Tax pitfalls of foreign investment in US real ...
WEBJun 17, 2013 · The US Foreign Investment in Real Property Tax Act (FIRPTA) was established in 1980 for the purpose of withholding the estimated amount of taxes which may be due on the gain of the disposition of a US real property interest from foreign persons. Daniel Gross, CEO of Axis International Realty, explores the intricacies of the provision.
US Inbound: Sale of partnership interest | International Tax Review
WEBMay 29, 2018 · We discussed the Tax Reform Act and Grecian Magnesite v Commissioner in the May edition of International Tax Review.The 2017 Tax Act added new Section 864(c)(8), providing that if a non-resident alien individual or foreign corporation owns, directly or indirectly, an interest in a partnership that is engaged in a trade or business within the US, gain or loss on the sale or exchange of all (or ...
Top 10 transfer pricing cases from 2022 | International Tax Review
WEBDecember 12, 2022. ITR picks 10 cases that made the headlines, with McDonald’s France, BlackRock, and Maersk Oil and Gas all making the list. It’s time for ITR’ s annual review of the biggest transfer pricing disputes of the year. Once again, multinationals found themselves up against determined tax authorities in high-stakes cases across ...