Taxation
By Roberto M. Cagnazzo, Studio Tributario Cagnazzo
The Italian Budget Law 2018 has introduced substantial modifications to the domestic definition of permanent establishment (PE). The changes consist mainly in the redefinition of the traditional classification and criteria for the identification of the ‘material’ and ‘personal’ PE. The lawmaker has made these changes in line with the new provisions of the OECD Base Erosion and Profit Shifting project (BEPS), the OECD Model Tax Convention on Income and on Capital and the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS.
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Assurance
By Saul Jimenez, Kutchins, Robbins & Diamond, Ltd. (KRD)
The items below detail various types of U.S. stock options that can be made available to staff and management. An interested company will need to have a valuation performed annually to determine the value of the company’s stock in order to properly account for any of the options below.
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Taxation
By Sergio Guerrero Rosas, Guerrero y Santana, S.C.
It’s true that it has been a slow year in taxation but we can’t take our minds off what is yet to come for Mexico; major changes will be happening and we have to be prepared for them.
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Taxation
By Prof Robert Anthony, Anthony & Cie
The question of preparing annual accounts for an SCI (Société Civile Immobilière) appears to be clear under French domestic tax law. Some foreign and French resident clients contacted us wondering whether accounting should be held for a French SCI. These clients have had different replies from different practitioners. The purpose of this article is to show the necessity for tax purposes to hold annual accounts.
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Taxation
By Howard Bakrins, Kutchins, Robbins & Diamond, Ltd. (KRD)
2018 brings in sweeping reforms to the US taxation of corporations. Among the many changes are lower corporate tax rates and changes to some corporate deductions, as well as changes to the taxation of foreign subsidiaries of US corporations.
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Taxation
By Bernhard Schwechel, FACT GmbH
Germany’s Tax Authorities issued a decree in 2016 on the procedure for amending a tax return under sec. 153 of the General Tax Code (AO). It raised the issue of an internal control system for tax purposes and contains general guidance about the conditions that must be fulfilled to use the provision, as well as the criteria for distinguishing between a simple amendment procedure and a voluntary self-disclosure procedure (VSP).
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Taxation
By CA Anjali Kukreja, RN Marwah & Co LLP Chartered Accountants
Tax law before Budget 2018 amendment: Provisions of section 115-O of the Income Tax Act, 1961(„Act‟) provide for application of Dividend Distribution Tax („DDT‟) @ 15% (plus applicable surcharge and cess) on the amount of dividend (declared distributed or paid by a domestic company). Further, provisions of section 115-Q provide that the expression dividend for the purpose of section 115-O would include deemed dividend under section 2(22)[sub-clauses (a),(b),(c) and (d)] of the Act.
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Taxation
By Heike Kempf, WSB Wolf Beckerbauer Hummel & Partner Steuerberatungsgesellschaft mbH
The OECD Base Erosion and Profit Shifting (BEPS) Programme involves over a 100 countries collaborating on its implementation. BEPS Action 15 is the development of The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Countries can use the MLI to implement various treatyrelated measures.
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Taxation
By Roberto M. Cagnazzo, Studio Tributario Cagnazzo
The Italian Budget Law 2018 has extended the super-depreciation and the hyper-depreciation provisions to all new tangible assets purchased or leased under a finance lease agreement from January 1, 2018 to December 31, 2018. In addition, the assets purchased or leased by the longest terms of June 30, 2019 (in case of super-depreciation) and December 31, 2019 (in case of hyper-depreciation) can benefit of the mentioned provisions on condition that the order of the asset has been accepted by the supplier and at least 20% of the purchase price has been paid by December 31, 2018.
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Taxation
By Emily Burns, Offit Kurman
In 1961, the United States Supreme Court held that even income generated from illegal activity is subject to federal taxation, which means cannabis businesses must pay federal income taxes, just like federally-legal businesses. However, because the possession, manufacture, and distribution of marihuana [1] remains illegal under federal law, cannabis businesses are subject to unique tax rules. This is the first of two blog posts covering the unique tax law restrictions applicable to businesses operating in the cannabis industry.
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