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CBSA Announces 2017 Trade Verification Priorities

As has become its customary practice at this time of the year, the Canada Border Services Agency (CBSA) has published its trade verification (audit) priorities for the coming year. The audits will cover three programs that...more

Enforcement of Foreign Tax Claims

In many cases we have handled the taxpayers were dual nationals who have not only failed to adequately disclose and report foreign bank account and income to the IRS, but have also failed to report to the other country. This...more

Colombia's tax bill - transfer pricing updates

Colombia's newest tax bill, enacted on December 29, 2016 through Law 1819 of 2016, modifies (among others) the following sections of the tax code, related to the transfer pricing regime...more

Registration with the RF tax authorities aimed at payment of VAT by foreign e services providers

Dentons’ Russia Tax practice would like to remind readers that, starting 1 January 2017, foreign companies providing e-services are required to undergo special tax registration according to the procedure of Clause 4.6 of...more

Kyiv Tax Newsletter (Ukrainian)

Subsistence minimum and minimum wage - On 21 December 2016 the Parliament of Ukraine adopted the Law “On the State Budget of Ukraine for 2017” No.1801-VIII (hereinafter, "the Law on State Budget"). The Law on State...more

New IRS Reporting Rule Could Bite Unwary Foreign Investors

There are two main sources of reporting requirements for foreign investors in the United States — the Internal Revenue Service and the Bureau of Economic Analysis. The IRS recently upped its game by requiring reports from...more

Kyiv Tax Newsletter

Subsistence minimum and minimum wage - On 21 December 2016 the Parliament of Ukraine adopted the Law “On the State Budget of Ukraine for 2017” No.1801-VIII (hereinafter, "the Law on State Budget"). The Law on State...more

Complying with legal requirements on controlled foreign corporations

Dentons’ Russia Tax practice would like to remind readers that starting in 2017 individuals and legal entities that are deemed Russian tax residents must annually file notices about foreign entities and unincorporated...more

Worries about NAFTA Take Back Seat to Potential “Border Adjustment Tax”: Law Firm of Miller Canfield

Companies importing goods into the U.S. should pay very close attention to the serious discussions now taking place in Washington, D.C. regarding a major restructuring of the U.S. corporate income tax scheme to include a...more

The favourable tax regime of new Italian residents

The 2017 Budget Law introduced (starting from fiscal year 2017) favourable provisions for people wishing to become tax residents in Italy. It is aimed at wealthy individuals who wish to bring in new capital resources. The...more

ITC Solicits Public Comments On MTB Petitions - 45-Day Comment Period Open Until February 24, 2017

The U.S. International Trade Commission (“ITC”) is now accepting public comments on Miscellaneous Tariff Bill (“MTB”) petitions for duty suspensions and reductions that timely were filed with the agency by December 12, 2016,...more

HMRC Publishes Guidance on the Tax Treatment of Clawback of Remuneration in the UK

Since the financial crisis of 2008 / 2009, swathes of new regulations have been introduced governing various aspects of remuneration in the financial services sector. A key feature of these rules is the compulsory clawback of...more

Client Alert on the Law On Non Cash Settlements

On 16 December 2016 the President of the Republic of Azerbaijan signed the law On Non-Cash Settlements (the “Law”). Below is a general summary of the Law...more

TTB Changes Under the Fall Edition of the Unified Agenda

On December 23rd, 2016 the federal government published its Fall edition of the “Unified Agenda” – a bi-annual compilation of all ongoing federal rulemaking projects. Attached is a copy of the TTB detail from this latest...more

Why are Americans Working Abroad Giving Up Citizenship?

Many Americans working abroad are renouncing their citizenship because of tax requirements imposed by U.S. tax laws. For Illinois residents employed overseas, an immigration lawyer in Chicago can explain tax laws that have an...more

Some Tax Law Changes That Take Effect in 2017

No new tax legislation has come forth yet, but per tax laws passed in prior years, some changes in the law will occur in 2017. Chief among them...more

Real Estate Advisory: Canada Revenue Agency Announces Changes to Treatment of U.S. LLLPs and LLPs

The Canada Revenue Agency (CRA) recently announced a change in the treatment of U.S. limited liability limited partnerships and U.S. limited liability partnerships (the “Entity Types”) for Canadian tax purposes. For Canadian...more

Amendment Protocol to the India-Singapore Tax Treaty Inked

Capital gains on alienation of shares to be taxable by India. The India-Mauritius tax treaty was amended by way of a protocol signed by the two countries on May 10, 2016—marking a landmark shift in India’s taxation...more

2016 Year-End Tax Update: Okay, Now What?

In last year’s materials, loosely styled “Make America Great Again!,” we ruminated upon (and also thought about) what role, if any, federal income taxes might play in helping to make America great again, once the interminable...more

India Amends Capital Gains Tax Treaty With Singapore

The Government of India amended its double taxation avoidance agreement (DTAA) with Singapore on December 30, 2016. The amendment allows the Government of India to levy source-based capital gains taxes on foreign direct...more

New Tax Information Exchange Agreement Between the United States and Argentina

The governments of Argentina and the United States signed on December 23rd, 2016, a new tax information exchange agreement (“TIEA”). Jack Lew, U.S. Treasury Secretary, stated that the TIEA will allow for important...more

Tax Reform in the New Administration

The upcoming change in administration, combined with retained Republican control of both houses of Congress, is expected to result in significant changes in the federal income tax system, on both the domestic and...more

Bankers, Do your US Clients tell you everything that you need to know?

Given the information publicly revealed by “Panama Papers”, and recent IRS reminders to out-of-compliance US Taxpayers to come into full compliance with their federal tax obligations, it is critical that Bankers and Financial...more

New Amendments to the Tax Code

On 16 December 2016 the President of the Republic of Azerbaijan signed a law amending the Tax Code (the “Amendment Law”). These are the long-awaited amendments whose adoption was expected after the President signed on 4...more

Financial Services Quarterly Report - Fourth Quarter 2016: UK Autumn Statement 2016: Tax-Related Impact for the Financial Services...

In his first (and last) Autumn Statement, the Chancellor of the Exchequer, Philip Hammond, announced a number of tax measures affecting the financial services industry, although many of these changes had been the subject of...more

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