U.S. Government Shutdown Impacts the IRS Capability to Process Returns

January 03, 2019

As the saying goes, "When you have lemons; Make lemonade"

Due to the government shutdown the IRS is expected to operate at 12% capacity.  This offers a unique window to have your return submitted with a drastically reduced change of the return being further scrutinized.  

The IRS will begin to accept business returns on January 8th and individual returns on January 28th, 2019

Happy New Year

January 01, 2019

Ascent Strategies International would like to thank you for your continued patronage and express our wishes to you and your family for a Happiest of New Year's

To a prosperous 2019!

Poland Announces Important Changes in Polish Tax Legislation For 2019

December 20, 2018

The Ministry of Finance has recently published a draft bill aiming to amend to the personal income tax (PIT) and corporate income tax (CIT) laws as of 1 January 2019 (the "2019 Tax Bill").

 

The proposed changes are of a very comprehensive nature and, according to the explanatory memorandum, are aimed at (i) "simplification" and (ii) "tightening up" of the tax system. 

Luxembourg Coalition Agreement: Proposal of Tax Measures

December 06, 2018

The new coalition composed of DP, LSAP and Déi Gréng released an agreement for the formation of the future government.

In this Agreement, the Luxembourg government underlines its wish to maintain an attractive economic environment, including through a competitive economic and tax framework and significant investments in the country's infrastructure. The framework will encourage entrepreneurship and will enhance efforts aiming to diversify the financial market and the economy for the benefit of companies emerging from high-tech sectors.


From a purely tax perspective, this Agreement which sets strategic goals until 2023, provides directions on individual taxes, corporate taxes as well as green taxes.

AMLO Inaugurated As Mexico’s President, Vowing To Transform The Country

December 01, 2018

Andrés Manuel López Obrador, 65, known by his initials AMLO, took office as potentially the most powerful Mexican president in decades.

 

Not only did he win 53 percent of the vote in a three-way race, but his party cinched a majority in both houses of Congress and gained control of numerous state legislatures.

Dutch Tax Plan 2019 Adopted by the House of Representatives

November 20, 2018

On the 15th November 2018, the House of Representatives of the Dutch Parliament adopted legislative proposals that incorporate the tax measures of the 2019 Tax Plan and the EU Anti-Tax Avoidance Directive (ATAD 1).

 

The legislative proposals were initially made by the Dutch Government on 18 September 2018 and were later amended following political debate.

Spain's Draft Bill on Digital Services Tax

November 15, 2018

The Spanish Treasury opened public hearing proceedings on the draft bill on Digital Services Tax, which creates a new tax, the main characteristics of which are as follows:

  • Taxable event: the new tax is levied on;

    • Online advertising services

    • Online intermediation services offering users with a multi-sided digital platform allowing them to: (i) facilitate direct delivery of underlying goods or services directly between users or (ii) reach other users.

    • User data transfer services generated through the activities users carry out on the digital platform.
         

  • Exempt are: i) online advertising services when the only or sole purpose is to provide digital content to users or provide them communication or payment services; ii) online advertising services
    and data transfer services provided by a “trading venue”, a “systematic internaliser” or “regulated crowdfunding provider” (Directive 2014/65/EU).
        

  • Taxpayers: taxpayers exceeding the following two thresholds (calculated at group level):

    • Net turnover in the preceding calendar year in excess of 750 million euros; and

    • Total amount of income subject to Spanish digital tax, corresponding to the previous calendar year, greater than 3 million euros.
         

  • Tax base: calculated on the gross income, excluding indirect taxes, obtained from the provision of digital services to users located in Spain. There are special rules for calculating this income.
       

  • Tax rate: 3%.
       

  • Formal obligations: Declarations will be submitted on a quarterly basis. A specific regime is established for formal obligations, infringements and penalties. 

Thailand Enacts New Copyright Act

November 11, 2018

In accordance with the Marrakesh Treaty to Facilitate Access to Published Works for Persons Who Are Blind, Visually Impaired, or Otherwise Print Disabled (“Marrakesh Treaty”), the Proposed Amendment to the Copyright Act to provide an exemption for disabled persons to reproduce or adapt copyrighted works was announced in the Government Gazette on 11 November 2018 as the Copyright Act (No. 4) B.E. 2561 (2018).

 

The new law will take effect in 120 days, on 11 March 2019.

IRS Announces the Identification and Selection of Five Large Business and International Compliance Campaigns

October 30, 2018

The IRS Large Business and International Division (LB&I) announced on October 30, 2018.

 

The approval of five further compliance campaigns related to international tax matters. These new campaigns are in addition to previously announced international tax compliance campaigns and demonstrate the ongoing efforts and focus of the IRS on these areas.

 

Both US taxpayers and international financial institutions should pay close attention to these campaign issues in connection with their ongoing compliance obligations.

IRS Releases Proposed GILTI Guidance

October 02, 2018

Ascent Strategies International has prepared an Advisory Alert on the recently proposed regulations under Section 951A that were released by the IRS.

 

The proposed regulations provide guidance with regard to various mechanical and computational aspects of the GILTI regime, along with rules for reporting requirements.

 

The proposed regulations do not contain any rules on the foreign tax credit, (including rules on expense allocation to the section 904(d)(1)(A) GILTI basket) as it relates to GILTI.

 

Our Advisory Alert provides an in-depth analysis on how the proposed regulations will impact taxpayers.  Contact your ASI Advisor for more information

China Announces New Tax Incintives to Foreign Investors

September 28, 2018

TIn a bid to attract foreign investment, China offers a range of tax concessions to FIEs and foreign enterprises. The following are some of the major preferential policies.

- Concessions on VAT and Customs Duty

- Concessions on Enterprise Income Tax

- Individual Income Tax Concession for Foreigners

- Tax Concessions for Central and Western Regions

The Netherlands: The Dutch Government Released Its Budget 2019 Containing The Tax Plan for 2019

September 18, 2018

The Dutch government released its Budget 2019 containing the Tax Plan for 2019, which includes some significant amendments to Dutch tax laws.

The basis of the Tax Plan was laid down in the newly elected government's coalition agreement of October 2017, whereby parties agreed to a comprehensive tax reform in the coming years.

The Tax Plan 2019 contains several important measures that significantly affect Dutch tax legislation. It aims to implement stricter rules, amongst others imposed by EU legislation, yet at the same time maintain a competitive business climate. As a next step, the measures announced yesterday will be discussed in Parliament in the coming weeks and, when approved, new laws will be implemented effective 1 January 2019 (unless otherwise indicated).

Belgium: New General Income Tax Withholding and Reporting Obligations

September 06, 2018

The Belgian government proposed new legislation introducing:

  • A general income tax reporting obligation for all forms of equity compensation as of January 1, 2018; and

  • A general income tax withholding (and reporting) obligation for all forms of equity compensation as of January 1, 2019.

Venezuelan Increases VAT General Rate from 12% to 16%

September 01, 2018

Under Article 27 of the Venezuelan Value Added Tax Law, the National Executive may modify the tax rate between 8% and 16%.

 

Through Decree No. 67, the President of the Republic set the general tax rate applicable to VAT at 16% (formerly established at 12%). The new rate will enter in force on 1 September 2018 and will apply to the remaining months of fiscal year 2018 and fiscal year 2019.

 

Pursuant to the mentioned Decree, the National Executive may make the necessary adjustments to the financing approved by the National Constituent Assembly or the Venezuelan Supreme Court of Justice.

President Trump Signs The Foreign Investment Risk Review Modernization Act

August 13, 2018

President Trump signed into law the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), the most significant changes to the law governing the Committee on Foreign Investment in the United States (CFIUS or Committee) since the creation of the US foreign investment regime in 1988.

 

Although prompted primarily by national security concerns with Chinese investments, the legislation will affect investments by all foreign investors. The changes reflect a trend across advanced markets for greater scrutiny of inbound investments.

China Extends Deed Tax and Land Appreciation Tax Exemption for Enterprise Restructuring

August 01, 2018

China Tax Update July 2018

  • China completes the tax administration reform to merge state and local tax bureaus

  • New SAT bulletin provides document requirements for EIT deduction

  • TASE tax incentive expands to more industries

  • Super deduction incentive expands to cover expenses incurred for outsourced offshore R&D activities

  • China renews EIT incentives for integrated circuit manufacturing enterprises

  • China unifies the threshold for small-scale VAT taxpayers

  • VAT rates in various sectors reduced by 1%

  • China extends deed tax and land appreciation tax exemption for enterprise restructuring

Argentina and Brazil Sign Amendment Protocol to Double Taxation Treaty

July 21, 2018

A note of the Ministry of Foreign Affairs reported that the Amendment Protocol (the Protocol) to the Argentina-Brazil Double Taxation Treaty will enter into force on 29 July 2018.

The Protocol was previously approved by the legislative branch of both countries, and amended, among other things, the existing permanent establishment, interest, royalties, double taxation, exchange of information and limitation of benefits provisions.

According to the terms of the Protocol, it will be applicable as from 1 January 2019.

German Real Estate Transfer Tax – Intended Cut Back of Share Deal Privilege

July 14, 2018

the Finance Ministers of the 16 German Federal States agreed on significant changes to be introduced to German tax law for reducing planning opportunities that are aimed at avoiding real estate transfer tax (RETT).

1. Expansion of taxable events for corporations owning real estate.

2. Extension of the relevant holding period from 5 to 10 years.

3. Reducing the 95% threshold to 90%.

Malaysia's Final List of Reportable Jurisdictions

July 03, 2018

The Malaysian Inland Revenue Board (IRB) published the final list of reportable jurisdictions for the reporting of financial account information of the year 2017. Brazil, France, Hong Kong, Hungary, Indonesia, Liechtenstein, Lithuania, Poland and Uruguay are the latest jurisdictions which were added on to the list, with the final list consisting of a total of 42 jurisdictions.

New Law of Ukraine's "Limited Liability and Additional Libiality Companies" Came Into Force

June 17, 2018

On 17 June 2018, the Law of Ukraine On Limited and Additional Liability Companies came into effect. Current provisions of a limited liability company (LLC) charter will remain effective until the earlier of 17 June 2019 or the date when any amendments to a charter are introduced by the participants. After such date, the provisions of the law will override the conflicting provisions of the LLC charter. The provision of the law on expulsion of participants in the case of a participant’s death or liquidation will become effective on 17 June 2019.

The law fundamentally changes the rules for LLCs in Ukraine. It provides participants with wide discretion in establishing the rules on LLC corporate governance and transfer of participatory interests.

Russian Federal Tax Service Further Tightens Beneficial Ownership Requirements

June 06, 2018

The Russian Federal Tax Service recently issued its new guidance summarizing Russian court practice on applying the Russian beneficial ownership rules.

 

This guidance significantly increases requirements for foreign recipients of Russian source income in order to qualify as beneficial owners eligible for tax treaty benefits.

 

Although intended as an anti-avoidance measure, this new approach may negatively affect many proper holding and treasury companies, dramatically increasing substance requirements and forcing extensive disclosure.

Hong Kong Introduces An Enhanced Tax Deduction For Qualifying R&D Expenditures

June 05, 2018

The Inland Revenue (Amendment) (No. 3) Bill 2018 (the "Bill") proposing an enhanced tax deduction regime for qualifying research and development (R&D) expenditures.

The enhanced tax deduction, which was proposed by the Chief Executive in her 2017 Policy Address, is intended to encourage more enterprises to invest in R&D activities in Hong Kong.

Malta Creates Cryptocurrency Regulation Framework

May 23, 2018

The country makes good on its promise to be a welcoming home to legitimate cryptocurrency businesses. 

The government of Malta published three new bills which together create a regulatory framework for cryptocurrency.

The three bills are: the Virtual Financial Assets Bill, the Malta Digital Innovation Bill and the Innovative Technology Arrangements and Services Bill.

Proposed Changes of Audit Period for UK Tax Havens 4 years to 12 Years

May 16, 2018

MRC proposes extending the assessment time limit to a minimum of 12 years for mistakes or non-deliberate errors involving offshore income, gains or chargeable transfers.

This means HMRC could have up to 12 years to investigate individuals with any connections to ‘offshore matters’. This is looking far beyond tax evaders and could severely impact those who are fully UK tax compliant

Are You Ready for GDPR And The EU's Huge Data Privacy Shake Up?

May 07, 2018

Thanks Cambridge Analytica! After claims surfaced last month that Cambridge Analytica used data harvested from millions of Facebook users without their consent, the EU took action!

The General Data Protection Regulation (GDPR), which comes into force on 25 May, will be the biggest shake-up to data privacy in 20 years. The new law will make the consequences of failing to protect personal data for banks and others far more serious.

U.S. Tax Reform Resulting In Massive Tax Bills For Thousands of Canadian Residents

April 30, 2018

A law meant to help U.S. corporations sheltering funds offshore is unintentionally causing harm to Canadian residents with U.S. or dual citizenship who own Canadian corporations.

 

A one-time retroactive tax being levied on all of their companies' retained earnings going back to 1986 is required by June 15, 2018. 

Tax Law Quirk Could Help Apple and Microsoft Lower Their Tax Bills

April 03, 2018

The Internal Revenue Service is providing some relief for companies facing looming tax bills after they stockpiled trillions of dollars offshore free of U.S. income tax

Bitcoin in Malaysia: Will The Malaysian Government Ban Bitcoin Trade?

March 23, 2018

Malaysia's central bank, Bank Negara, is expected to outline its stance on bitcoin in the near future with the publication of a cryptocurrency "concept paper"

Dutch Government Targets Tax Avoidance With Withholding Tax

February 23, 2018

On 23 February 2018, the Dutch State Secretary of Finance published a letteroutlining the Dutch government’s intention to introduce measures against tax avoidance by introduction of a new withholding tax on intra-group payments to low-tax jurisdictions of interest and royalties (by 2021) as well as of dividends (by 2020), the latter coinciding with the abolition of the current dividend withholding tax

Swiss Federal Supreme Court Decides To Limit Information Given To U.S. Internal Revenue Service

February 21, 2018

The Swiss Federal Supreme Court (Court) addressed the issue of whether in response to a request for information by the IRS under the exchange of information clause of the US-Swiss Double Taxation Treaty, the Swiss Tax Administration (STA) has to redact the names of bank employees and other third parties

Caterpillar Expects No Material Impact Of Tax Case

February 15, 2018

Caterpillar Inc said it will vigorously contesting the $2.3 billion tax and penalties for certain years proposed by the U.S. Internal Revenue Service

Singapore’s Inland Revenue Authority Publishes Tax Guidance for 2018

January 03, 2018

Singapore’s Inland Revenue Authority (IRAS) has published an e-Tax Guide providing taxpayers with guidance on the mutual agreement procedure (MAP) under Singapore’s tax treaties. The guidance contains a wealth of information in relation to the interpretation and application of the common provisions found in Singapore’s tax treaties

U.S. President Trump Signs New Tax Law

December 22, 2017

U.S. President Donald Trump on Friday signed into law H.R. 1, known as the Tax Cuts and Jobs Act, which makes widespread changes to the Internal Revenue Code. Almost all of its provisions, including a lower corporate tax rate of 21% and lower individual income tax rates, go into effect January 1, 2018

IRS Wins Court Case Against Bitcion. Coinbase Must Release Users Information

November 30, 2017

In a ruling, a federal court judge ordered San Francisco-based Coinbase to comply with a summons that requires it to identify Coinbase user accounts, which have accounted for nearly 9 million transactions.

The IRS is now set to collect back taxes from thousands of customers of the digital currency exchange who failed to report bitcoin transactions.

Portugal Implements New Wealth Tax

September 08, 2017

A year ago there was speculation that the new socialist government could introduce an inheritance tax. This has not happened, but a ‘wealth tax’ on property was introduced instead, which affects properties or a financial interest in them worth over €600,000

How Donald Trump Shifted Kids-Cancer Charity Money Into His Business

June 06, 2017

Trump National Golf Club in Westchester County, New York, in September plays host the Eric Trump Foundation golf invitational. Year after year, the formula is consistent: 18 holes of perfectly trimmed fairways with a dose of Trumpian tackiness...

Odebrecht: The World's Biggest Bribery Ring

April 05, 2017

It's the largest global corruption scandal in modern history.

 

Its web of bribes spread over four continents, implicated presidents and involved 12 countries. It also prompted the biggest fine ever levied by the U.S. Justice Department -- $3.5 billion.

Caterpillar Raided By IRS for Offshore Companies, What If They Visit You?

March 02, 2017

The IRS raided Caterpillar's headquarters over its offshore tax practices. The company is under investigation for shifting its corporate profits from the U.S. to a Swiss subsidiary. 

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