By Robert S. Jacobson, Kutchins, Robbins & Diamond, Ltd.
Research and Development (R&D) is often associated with sophisticated laboratory experimentation where cuttingedge technological product is created. However, the Internal Revenue Code offers a more flexible definition of research and development.
By David J. Kidd, Citroen Wells Chartered Accountants
Never-ending change: The UK Treasury cannot keep from changing the UK tax rules affecting foreigners, often referred to technically as ‘foreign domiciliaries’. At the time of the last major upheaval in 2008, there was a Treasury promise that there would be no further changes. In fact, there have been changes every year following 2008.
By Raghu Marwah and Anjali Kukreja, R.N. Marwah & Co LLP
1. Introduction of new law and its amendment
Before the insertion of section 115BBDA, there was loss to revenue, as high dividend income recipients (individual, HUF or firm) who would have been taxed at 30% had their tax liability discharged through DDT in the hands of the company at around 15%. Hence, to plug this loss of revenue, the Finance Bill 2016 inserted section 115BBDA into the Income Tax Act 1961 (hereafter the ‘Act’) with effect from 1 April 2017.
By Alejandro Fernando Toulet Lazos and Bridget Guzman, Toulet, Gottfried, Dávila y Martínez, S.C.
Currently, maquiladoras entities import their raw materials into Mexico and thereafter export a finished product. However, what happens if instead maquiladoras sell their products into the Mexican domestic market?
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.
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.
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.
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.
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.
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).
