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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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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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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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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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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