By Howard Bakrins, Kutchins, Robbins & Diamond, Ltd. (KRD)
US corporations that generate income from export activities should consider if the foreign-derived intangible income (FDII) deduction applies. The Tax Cuts and Jobs Act (TCJA), passed in 2017, made significant changes to the taxation of foreign income of US businesses. One of these changes was the creation of the FDII deduction.
By Joanne Fay, Funaro & Co. PC
Non-US businesses may do business in the US through US corporations, especially “blockers”. The Tax Cuts and Jobs Act in 2017 created a surprising new regime for certain US subsidiaries in foreign-parented groups. Depending on the group’s structure, certain non-US subsidiaries may now be deemed to have US shareholders, and that creates the risk of unplanned Subpart F, Section 965, and GILTI income inclusions until the US Congress fixes the problem.
By Mikhail Khaletsky, Nektorov, Saveliev & Partners
The use of tax benefits by foreign holding companies in earning passive income, such as dividends or interest, from Russia, requires such companies to provide proof of an actual right to the income.
By Dr Sergio Finulli; COMMA 10 Chartered Accountants & Lawyers
The EU ATAD (European Union Anti-Tax Avoidance Directive) No. 2016/1164 introduced a general anti-abuse rule in Article 6 that not only replaces and standardises the anti-abuse rules included in the three directives which regard corporate income tax (company mergers, parentsubsidiary, interest and royalties), but also extends the scope in the national legislations of the member states.
By Roberto M. Cagnazzo, Studio Tributario Cagnazzo
According to the Italian Income Tax Code, non-resident individuals and companies (without a permanent establishment in Italy) are subject to taxation only on income produced in the territory of the State in application of the territorial principle of taxation.
By Susann Roll, Benefitax GmbH
International online trade has become a huge business sector, in which it is often easy for traders to avoid VAT payments for sales, which are in fact VAT liable. To make VAT fraud more diffcult, new German legislation came into effect on 01 January 2019, which makes electronic marketplaces like Amazon and eBay liable for the VAT liability of the traders using their platform.
By Béla Kakuk, BPiON Services Ltd.
One of the most important objectives of the international taxation regime is to allocate taxation where profit and value is generated in order to guarantee trust over truthfulness of tax regimes and effective taxation sovereignty of local governments. The European Unions Anti-Tax Avoidance (ATAD) (2016/1164/EU) directive brought new rules preventing tax evasion and aggressive tax optimisation.
By David Pritchard, Mander Duffill
This article focuses on the tax benefits of Research and Development (R&D) and making a claim through the small and medium-sized enterprises (SME) scheme. There is also a large company R&D scheme; however, it was felt that the SME scheme is likely to be of more relevance to GGI members.
By Andreas Hänggi, Treuhand-und Revisionsgesellschaft Mattig-Suter & Partner
The Swiss people voted “yes” at a referendum held on 19 May 2019, regarding the Swiss tax reform and AHV financing (“TRAF”). Based on this positive vote, Switzerland continues to offer a stable and reliable tax environment and remains one of the most attractive business and tax locations.
By Darlene Hart and James Debate, US Tax & Financial Services
A US Supreme Court ruling last June is expected to impact every company that sells goods or services into the US within months, or even weeks and days. In many places, it has already begun.