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Once again, we find ourselves faced with a proposal attempting to target and provide special tax rules for income generated in the digital economy. As was the case in the previous year’s budget proposal, the Administration’s...more
For years, both the New York State Department of Taxation and Finance (the “Department”) and the New York City Department of Finance have aggressively sought to classify receipts generated by electronic or online service...more
Why it matters -
With the U.S. Supreme Court’s denial of certiorari, the Board of Governors of the Federal Reserve Board’s interchange rules will stand. The justices declined to hear an appeal from retailers without...more
The New York State Department of Financial Services (“NYDFS”) released its revised proposed BitLicense regulations on February 4, 2015. Changes from NYDFS’ initial proposed regulations are listed below. Among the more...more
The IRS has unveiled a secure web application, the International Data Exchange Service (IDES), for cross-border data sharing. IDES will allow Foreign Financial Institutions (FFIs) and tax authorities from other countries to...more
The ATO released a draft ruling on the GST treatment of bitcoin transactions on 20 August 2014. A final version of that ruling, GSTR 2014/3, was released on 17 December 2014. While the ruling deals specifically with bitcoin,...more
On December 5, 2014, the New York Department of Taxation and Finance (Department) released TSB-M-14(5)C, (7)I, (17)S. This (relatively short) bulletin sets forth the treatment of convertible virtual currency for sales,...more
On December 5, the New York State Department of Taxation and Finance (DTF) issued the memorandum “Tax Department Policy on Transactions Using Convertible Virtual Currency.” The memorandum clarified that under New York law,...more
This article highlights a number of interesting federal tax developments that were brought to the table during the 2014 calendar year. Developments discussed in this article include the 18-month transitional period for the...more
On December 5, 2014, the New York State Department of Taxation and Finance issued TSB-M-14(5)C, (7)I, (17)S, explaining its policy regarding convertible virtual currency....more
The Ministry of Finance and the State Administration of Taxation jointly issued the Circular, on Issues regarding Improving Enterprise Income Tax Policies ("EIT") for Technologically Advanced Service Enterprise ("ATSE")...more
As expected, the CRA has formally announced the details of its collaborative efforts with CPA Canada.
The CRA recently spoke about this collaboration at the Toronto Centre CRA-Tax Professionals breakfast seminar....more
On September 16, 2014, the Organisation for Economic Cooperation and Development (“OECD”) released a report on Action 1 of the OECD/G20 Base Erosion and Profit Shifting Project (also known as the “BEPS” project) titled...more
When it comes to Bitcoins and other convertible virtual assets, anonymity may not be all it’s cracked up to be. For one thing, an underlying assumption is that individuals who keep their financial transactions hidden have...more
On November 10, United States Trade Representative Michael Froman announced a major breakthrough in negotiations with China to eliminate tariffs on information technology products by expanding the scope of the International...more
November Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts -
The November Section 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more
In Part I of this series, we discussed the IRS guidelines on the taxation of gains and losses associated with convertible virtual currency. In this post, we will focus on the taxation of income--wages, self-employment income...more
Cohen & Company recently hosted “25 Way to Drive Profitability,” a workshop in Youngstown geared specifically toward manufacturers. Beginning with an overview by Rick Schiraldi of the Valley’s manufacturing roots and history,...more
Ecuador will soon be the first country in the world to have digital currency issued by a central bank. Although the new Ecuadorian currency won’t necessarily function like Bitcoin, Litcoin, Peercoin and Freicoin, or other...more
The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast.
INDIVIDUAL INCOME TAX...more
The Italian Government recently approved the “patent box”, a tax relief system for the incomes deriving from the exploitation of industrial property.
This could be a good news. Around 6 months ago we campaigned for...more
Newly published Brazilian Interpretative Act (Ato Declaratório Interpretativo) N. 7/2014 expresses the Brazilian IRS’s view regarding the tax treatment applicable to cross-border payments for the use of data centers located...more
While the use of crypto-currencies such as Bitcoin have increased in popularity in Australia there has very little legal clarification provided by regulators or legislators in relation to its legal status....more
The Consumer Financial Protection Bureau (“CFPB”) recently issued a consumer advisory summarizing the purported risks of virtual currencies, and announced that it would begin collecting complaints from the public regarding...more
Earlier today the ATO released its long awaited public guidance on the Australian tax and GST treatment of bitcoin and other crypto-currencies. This guidance was originally scheduled to be released on 30 June 2014. It was...more
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