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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
In another installment of the continuing saga surrounding the shuttering of the Silk Road online marketplace and arrest of its alleged creator and operator, Ross William Ulbricht (Ulbricht), a Southern District of New York...more
INVESTMENT INCENTIVES -
Generally, Canadian companies are expected to be self-supporting, but for companies involved in export development, there are several types of investment incentive programs which are designed to...more
On June 26, 2014, the U.S. Government Accountability Office (“GAO”) released a report, entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.” The report, delivered earlier to...more
Although the 113th Congress continues to see a dearth of legislation seeing final approval, over the past six months, Congress has managed to finalize Fiscal Year 2014 appropriations; address the Sustainable Growth Rate...more
The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more
June 30 is the deadline for taxpayers with a connection to foreign financial accounts to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). As this is the first year in which all FBARs must be...more
I have been posting a lot of FBAR-related posts lately. Here’s one more.
There has been a question whether owners of “bitcoins” and other virtual currencies that have non-U.S. aspects, are subject to annual reporting...more
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