Taxation

London

The UK Real Estate Tax Landscape is Changing

By Alex Barnes, Memery Crystal LLP

Between October 2018 and April 2020, there are various new changes of which clients need to be made aware. Some of these are anti- avoidance measures, some are to speed up HM Revenue & Customs’ (HMRC) collection of tax and some are new, or extensions to existing, reliefs. There will be opportunities and pitfalls. So, what are the changes?

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Taxation

research and development (R&D)

Mexican Tax Credits and Incentives

By Prof Sergio Guerrero Rosas, Guerrero y Santana, S.C.

With the entry of the new government in Mexico led by President Andrés Manuel López Obrador, new foreign- investment opportunities seem to open up, mainly in the Mexican southeast and in the northern border area, so here is a brief summary of some tax credits and current incentives in Mexico.

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Taxation

Indian Start-up

Foreign Investment in Indian Start-Ups

By Anjali Kukreja and Raghu Marwah, R.N. MARWAH & CO. LLP

Foreign investment in Indian startups, especially in high technology areas of artificial intelligence and consumer-facing apps, offer a big opportunity. The start-up space in India offers a win-win scenario for all, as foreign investors multiply their investment values with high IRR’s and Indian start-ups provide increased jobs, digitalised lifestyle and improved product innovations contributing to a more vibrant and rewarding economy, as well as a positive social impact.

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Taxation

Philadelphia

How is my interest classified for US tax purposes?

By Patrick J. McCormick, Drucker & Scaccetti

A threshold consideration sometimes inadequately explored by practitioners is how a foreign structure will be classified under United States tax rules. Frequently, advisors defer to foreign classification without fully examining details that could dictate alternative United States results. This article explores methods for determining classification, options for altering the default classification of an entity, implications of certain classification types, and considerations where the choice of entity classification is possible.

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Taxation

Moscow

Beneficial ownership concept and how this could affect your business in Russia

By Valeria Khmelevskaya, KBK Accounting

Nearly every Russian company belonging to multinational enterprises (MNE) has inter-company or cross-border arrangements or pays out dividends which might be especially attractive due to applicable double taxation treaty (DTT) incentives allowing reduced withholding tax rates or taxation only in the country of the recipient of such income. To apply such DTT incentives, a foreign recipient should provide a Russian company with the certificate of tax residency and confirmation of the recipient's actual right to such income prior to payment, otherwise the withholding tax (WHT) based on the Russian Tax Code shall apply (15% for dividends, 20% for other payments from Russian sources). Later on, a foreign company may still claim back the relevant WHT.

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Taxation

Sydney

Australia’s Anti-Hybrid Mismatch Rules

By Tony Nunes, Kelly+Partners Chartered Accountants

On 1 October 2018 Australia’s new hybrid mismatch laws officially came into force. The new rules are intended to implement BEPS Action 2, “Neutralising the effects of hybrid mismatch arrangements”.

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Taxation

Mexico City

New tax incentives in Mexico

By Sergio Guerrero Rosas, Guerrero y Santana, S.C.

Last December, the Chamber of Deputies approved the federal budget of 2019 for the first year of the government of the new President Andrés Manuel López Obrador (AMLO), which fixes a total net expenditure of 5 trillion 838 billion pesos. That is 23 billion 768 million pesos more than that proposed by the Ministry of Finance, as well as the Income Law of 2019, whose validity began on 1 January 2019.

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Taxation

The Taxation of Income from Cryptocurrencies in Various Jurisdictions (Part 14): United States

By Robert Crowley, Prager Metis CPAs

Recently, we have seen a growth in the sale or exchange of cryptocurrency, or the use of cryptocurrency to pay for goods or services. Unfortunately, guidance from the Internal Revenue Service (IRS) pertaining to related US income tax issues has not kept pace with the proliferation of cryptocurrency trading. This article highlights fundamental income US tax compliance issues for investors dealing or transacting in cryptocurrency.

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