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Mayer Brown

Normative Instruction RFB No. 2,205/2024: Regulation of the Effects Applicable to Cases Decided by CARF by Casting Vote

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On July 24, 2024, Normative Instruction No. 2,205/ of the Brazilian Federal Revenue Service (the "Instruction”) was published, that regulates Article 25, paragraph 9-A, and Article 25-A of Decree No. 70,235/1972, establishing...more

Williams Mullen

[Event] Winter Tax Forum 2024 - January 31st, Richmond, VA

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Join Williams Mullen partners for our in-person Winter Tax Forum on Wednesday, January 31, 2024. Our speakers, Farhad Aghdami, Jenny Connors, Conrad Garcia and Beth Hungate-Noland will present on partnership aggregators and...more

Mayer Brown

Brazilian IRS Clarifies Taxation of Credits Originated from a Court Decision

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On December 19, 2023, the Brazilian IRS published COSIT Answer to Advance Tax Ruling Request No. 308/2023 to clarify the Federal Tax Administration’s position regarding the levy of IRPJ, CSLL, PIS and COFINS on credits...more

Stikeman Elliott LLP

Announced Enhancements to the GST New Residential Rental Property Rebate

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On September 14, 2023, the Department of Finance Canada issued a news release (the “News Release”) regarding proposed legislation to be enacted in order to enhance the existing GST New Residential Rental Property (“NRRP”)...more

Goodwin

The South Korean K-Chips Act and Its Impact on International Companies and Investors

Goodwin on

For investors in enterprises in the Korean semiconductor industry and other national strategic industries, a new tax bill has been passed that (i) increases the base tax credits received by these enterprises to 25% (if...more

Kohrman Jackson & Krantz LLP

DON’T BE FOOLED! THE TOP 12 IRS SCAMS TO AVOID IN 2023

Every year, the IRS issues a list of the top 12 scams and schemes for taxpayers to take caution to avoid. While the first of April marked the annual “April Fools” period, I don’t want you to be fooled by IRS scams. So, while...more

Stikeman Elliott LLP

Court of Appeal of Québec Confirms Restrictions on the Tax Authorities’ Ability to Set Off Certain Claims in Insolvency...

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On December 22, 2022, the Court of Appeal of Québec upheld a Superior Court ruling that GST and QST input tax credits and refunds (“ITCs/ITRs”) claimed by a petitioner in connection with damage payments arising from...more

Orrick, Herrington & Sutcliffe LLP

Orrick Finance Italy – CELF Weekly Newsletter

n data 16 febbraio 2023, è stato pubblicato sulla Gazzetta Ufficiale n. 40 il D.L. del 16 febbraio 2023, n. 11 (il “Decreto Legge”), recante misure urgenti in materia di cessione dei crediti di imposta derivanti da tutte le...more

Ballard Spahr LLP

IRS Introduces a Domestic Filing Exception to Schedules K-2 and K-3

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Background - The Internal Revenue Service (IRS) introduced Schedules K-2 and K-3 beginning with tax year 2021. Schedule K-2 (Partners’ Distributive Share Items−International) and Schedule K-3 (Partner’s Share of Income,...more

Stikeman Elliott LLP

Reviewing the 2022 Fall Economic Statement and Other Announcements

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The past week was a busy one for Canada’s Department of Finance (“Finance”). On November 3, 2022, Finance released its 2022 Fall Economic Statement (the “Fall Economic Statement”) and the following day, it introduced Bill...more

Morgan Lewis

Inflation Reduction Act Creates New Corporate Minimum Tax

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The Inflation Reduction Act of 2022, signed by US President Joseph Biden on August 16, 2022, includes a new alternative minimum tax for corporations with profits of more than $1 billion....more

Stikeman Elliott LLP

GST/HST Input Tax Credit Claims: Does the Supporting Documentation Need to be Issued by the Supplier?

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On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more

Freeman Law

Foreign Earned Income Exclusion

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U.S. citizens and resident aliens who live abroad are taxed on their worldwide income. But such taxpayers may qualify for the foreign earned income exclusion, which allows certain taxpayers to exclude up to $112,000 (in...more

Orrick, Herrington & Sutcliffe LLP

Super deduzione per i costi di R&S e credito d’imposta – le novità del Decreto Fiscale

È prevista l'abrogazione del Patent Box e l'introduzione di una nuova opzione per la maggiore deducibilità del 90% dei costi di ricerca e sviluppo sui beni immateriali alternativa al credito d’imposta per attività di ricerca,...more

Orrick, Herrington & Sutcliffe LLP

Super Deduction for R&D Costs and Tax Credit - What's New in the Tax Decree

The tax decree October 21, 2021 no.146 provided the abolishing of the Patent Box regime and the introduction of a new optional regime providing an extra deduction (for Corporate income tax purposes as well as for the Regional...more

Freeman Law

The Tax Court in Brief - August 2021 #4

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 16 – August 20, 2021 - Catlett v. Comm’r, No....more

Hogan Lovells

Italy: new tax incentives for electronic payment instruments

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Following the tax relief introduced by Article 22 of Law Decree No. 124/2019, as converted into law by Law No. 157/2019, according to which merchants may obtain tax credits of 30% of the fees charged for the acceptance of...more

Proskauer - Tax Talks

Treasury’s Green Book Provides Details on the Biden Administration’s Tax Plan

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On May 28, 2021, the Biden Administration released the Fiscal Year 2022 Budget, and the “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Biden Administration’s Green Book Proposes Significant Changes to Tax Regime

On May 28, 2021, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for FY...more

Freeman Law

International Tax Treaty: China

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Quick Summary. The People’s Republic of China is the world’s most populous country and carries a rich cultural tradition. China is the world’s largest exporter and the second largest economy. A unitary socialist republic,...more

Jones Day

Italy: 110% Tax Deduction Enacted for Certain Energy and Anti-Seismic Works on Existing Buildings

Jones Day on

The Situation: For years, the Italian tax system has provided for certain tax deductions from income taxes in case of building restoration works. The Result: The tax deduction from income taxes has now been increased to...more

Hogan Lovells

Implementing rules for Superbonus 110% have finally been issued

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All implementing measures necessary to benefit from the Superbonus 110%, enacted by the so-called Relaunch Decree, have finally been set out by the Ministry of Economic Development and by the Italian Tax Authorities....more

McDermott Will & Emery

Special Report - Coronavirus Update - Monitoring of the Main Tax Measures/Subsidies Country-by-Country Overview

The Coronavirus (COVID-19) has governments across Europe, Asia, Africa, Australia, North and Latin America quickly evaluating and issuing modified tax-related measures to help support business investments and providing...more

McDermott Will & Emery

[Event] Tax in the City®: A Women's Tax Roundtable - March 12th, Seattle, WA

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Mark your calendars for our spring 2020 Tax in the City®: A Women’s Tax Roundtable in Seattle—a forum for women tax professionals to discuss technical state, federal and international tax issues in a collegial and...more

Orrick, Herrington & Sutcliffe LLP

Bilancio di Previsione dello Stato per l'anno finanziario 2020

(Legge 27 dicembre 2019, n. 160 pubblicata in Gazzetta Ufficiale serie generale 304 del 30 dicembre 2019). ...more

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