01/26/2022
This is because, for US tax purposes, gain on the sale of property is generally treated as tax-free foreign source gain in the hands of a foreign seller.
01/21/2022
In particular, the Final Regulations adopt a new “attribution requirement” (Attribution Requirement) that restricts the availability of FTCs to foreign taxes that the Treasury and the IRS consider to be similar to US taxes.
01/20/2022
As a reminder, effective 1 January 2019, the deemed tax credit regime whereby companies holding a Category 1 Business Licence were entitled to claim a deemed tax credit of 80% was abolished and replaced by a partial exemption regime on qualifying income.
01/14/2022
The government’s consultation seeks views on the proposed tax - which will be operated on a country-by-country basis - and its application in the UK, including who the rules apply to, transitional rules and how firms within scope should report and p
01/12/2022
Countries signing up to the OECD deal are not obliged to introduce the pillar two rules, but if they do so, they must follow the approach taken in the OECD model rules.
12/30/2021
There is an increasing overlap between legal and accounting, and so this partnership with Lawpath will ensure businesses right around Australia receive expert on demand advice to stay ahead and succeed with their business operations.
12/21/2021
An oligarch, a dictator’s aide and a beverage tycoon turned to America’s least populated state to shelter assets, the Pandora Papers show.