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MoFo New York Tax Insights - Volume 6, No. 4 - January 2014

In This Issue: FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net...more

Sale of dividend claims to third parties by non-resident taxpayers

Federal Ministry of Finance: If the capital gain is not taxable in Germany, the correspondent dividends are taxed. With its circular letter dated 26 July 2013, the Federal Ministry of Finance comments on the tax...more

Tax Newsletter - Second Edition 2013: A Review Of PRC And Hong Kong Tax Developments

In This Issue: *CHINA: - HEADQUARTER AND BRANCHES VAT FILING UNDER THE VAT PILOT PROGRAM - FURTHER CLARIFICATION ON BENEFICIAL OWNERSHIP OF DIVIDENDS UNDER DTA WITH HONG KONG - PE ON SECONDMENT...more

No 15% Qualified Dividend Rate For CFC Inclusion

Back in 2011, we reviewed a Tax Court case that determined that income inclusion under the controlled foreign corporation (CFC) rules, while taxed like a dividend at ordinary income rates, could not qualify for the lower 15%...more

The Gwartz Decision: The GAAR Is Not A Filler

In Brianne Gwartz v. The Queen, 2013 TCC 86, the Crown attempted to utilize the GAAR to recharacterize as dividends certain capital gains which had been realized by a family trust and allocated to the minor-aged taxpayers in...more

Expatriation Lite: Leaving The U.S. Tax System While Retaining Your Citizenship

As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more

Cyprus: The Day After - The sun will still shine bright

Introduction - Cyprus has been in the spotlight recently due to the negotiations with what has become known as the troika (the International Monetary Fund, the European Central Bank and the European Commission)...more

Readjustment of Taxation of Free Floating Dividends and of Fiscal Unity – Current Legislative Procedures

Reform of taxation of free floating dividends for corporate income tax purposes The German Parliament (Bundestag) and the German Federal Council (Bundesrat) reached an agreement regarding the taxation of free floating...more

Congress Approves The American Taxpayer Relief Act Of 2012, Preventing "Fiscal Cliff"

After much contention,Congress passed the American Taxpayer Relief Act of 2012, and President Obama signed the legislation on January 2, 2013. The Act avoids automatic sunset provisions that were scheduled to take effect...more

Estate Planning & Federal Tax Update - Winter 2013

With the American Taxpayer Relief Act of 2012 (the “ATRA ”) passed and the fiscal cliff safely averted, the time has come to turn your attention to your estate plan. What Did the ATRA Accomplish? The fiscal cliff...more

Rates of Change: The Effect of the American Taxpayer Relief Act of 2012 on Individual and Fiduciary Income Taxes

For all the public discussion in 2012 of the need for a significant reformation and restructuring of the Internal Revenue Code, the income tax provisions of the American Taxpayer Relief Act of 2012 (the 2012 Act) are at their...more

Estate Planning After the Fiscal Cliff Deal

Now that a deal averting the fiscal cliff has finally been reached, many of the tax and planning issues that have been mired in uncertainty for the past two years (and even longer in some cases) may be resolved. Numerous tax...more

How Will the American Taxpayer Relief Act of 2012 Affect You - Details of Legislation passed by Congress to Avoid Fiscal Cliff

On January 2, President Barack Obama signed into law the American Taxpayer Relief Act of 2012, H.R. 8 (ATRA), preserving many of the key tax provisions passed during the George W. Bush presidency, which were scheduled to...more

McNees Insights - Asset Planning and Federal Taxation - Winter 2013

2012 Tax Act - The American Taxpayer Relief Act of 2012 (the “Act”) was signed into law on January 1, 2013 to avert the tax law changes that were one part of the “fiscal cliff” facing our country’s economy (the other...more

American Taxpayer Relief Act of 2012: Tax Implications for U.S. Taxpayers Living Abroad

Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more

The American Taxpayer Relief Act of 2012 and What It Means to You

On Jan. 2, 2013, President Obama signed the “American Taxpayer Relief Act of 2012” (the “Act”) which was passed by the House and Senate the previous day to avoid the so-called “fiscal cliff.” The Act prevents many of the tax...more

American Taxpayer Relief Act of 2012 Approved by Congress and Signed by the President

Summary - President Obama on January 2, 2013 signed into law the American Taxpayer Relief Act of 2012 (the “Act”). The Act extends certain tax rates, tax credits, and other provisions previously enacted by other tax...more

The American Taxpayer Relief Act of 2012: Some Tax Certainty in an Uncertain World

On January 1, 2013, Congress averted the fiscal cliff with the passage of the American Taxpayer Relief Act of 2012 (Act), which was enacted when President Obama signed the Act on January 2, 2013. The Act provides a welcome...more

Fiscal Cliff II: What’s Next For Tax Reform?

On January 1, 2013, the Senate and House of Representatives passed the American Taxpayer Relief Act of 2012 (“ATRA”), signed into law by President Obama on January 2. ATRA averts the “fiscal cliff” by making permanent the...more

Fixing the Debt: Update on U.S. Fiscal Cliff Crisis (9th Edition) - January 1, 2013

THE LEGISLATION - Following a day of tumultuous House Republican caucus deliberations, at 11:00 pm, the House passed The American Tax Relief Act of 2012, a cliffhanger deal negotiated by Vice President Biden and Senate...more

Legal Alert: The Cliff-Hanger (Chapter One) is Over: Highlights of the American Taxpayer Relief Act of 2012

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the Act), effective as of January 1, 2013. In general, the Act made permanent for most taxpayers the tax rate cuts first enacted...more

Summary of Income Tax Provisions in the American Taxpayer Relief Act of 2012

As you no doubt are aware, Congress just passed, and the President just signed into law, the American Taxpayer Relief Act of 2012 (the “Act”). The Act is effective as of January 1, 2013. This summary addresses certain of...more

‘Fiscal Cliff’ Legislation Temporarily Extends Key Provisions for Businesses

As part of legislation enacted in early 2013 to avert the so-called “fiscal cliff,” Congress temporarily extended several beneficial tax provisions for businesses, including the research credit, the active financing exception...more

Last-Minute Fiscal Cliff Tax Deal Reached - Highlights of the American Taxpayer Relief Act of 2012

The United States plunged off the theoretical cliff New Year's Day, but the U.S. House of Representatives pulled us back by passing the U.S. Senate's version of the budget bill on New Year's Day, and lo and behold, we now...more

American Taxpayer Relief Act of 2012 Finally Settles Individual Federal Income Tax Rates for 2013 and Beyond

On January 1, 2013, the Senate and the House of Representatives passed the American Taxpayer Relief Act of 2012 (“ATRA”), averting the so-called “fiscal cliff.” The legislation, which was signed by President Obama on January...more

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