Tuesday, April 14, 2020

Final U.S. tax regulations transform cross-border financing - Lexology

Canadian companies that have been awaiting final guidance in this area have, in many cases, been in the difficult position of trying to assess how the proposed rules would impact current and future financing arrangements — leading some to be stuck in an awkward financing “holding pattern.” Like them or not, the final and proposed regulations provide a form of closure and allow Canadian businesses to turn the page and move forward with financing their U.S. operations.

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Many things are taking place:

Judge Grants Suspension Due to Absence of Fiscal Regulations Amid COVID-19 Pandemic in Mexico |

On April 3, 2020, the Third District Court of the State of San Luis Potosí, Mexico, granted a suspension in amparo Case Number 293/2020, in which Andres Manuel Lopez Obrador, President of the United Mexican States, is ordered to "issue the measures and actions to comply with Federal Tax Code Article 39, Section I, in the sense that he must issue, through general resolutions, a position on condoning or exempting, in whole or in part, the payment of contributions and their accessories,

Publisher: JD Supra
Twitter: @jdsupra
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Costa Mesa Approves Ordinance Lowering Business Tax on Legal Marijuana | Voice of OC

Costa Mesa has approved an ordinance that will reduce a business tax on all legal marijuana operations established in a city measure approved by voters in 2016.

The City Council voted 4-2 in mid-March to give final approval to the law that will reduce a 6% gross receipt tax to 1% on all distribution, manufacturing, research and development of legal marijuana, and will eliminate the tax for testing. The law goes into effect April 16.

California's Proposition 64 (also known as The Control, Regulate and Tax Adult Use of Marijuana Act) was approved in 2016 and legalized the adult use of marijuana statewide and created two state excise taxes: a 15% wholesale tax and a $9.25 per ounce cultivation tax (recently increased to $9.65).

Publisher: Voice of OC
Date: 2020-04-14T07:13:27-07:00
Twitter: @voiceofoc
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Confused? Simplifying The Complexities Of The Paycheck Protection Program And Tax Reform

Coronavirus Aid, Relief, and Economic Security (CARES) Act provides approximately $377 billion worth ... [+] of relief to small businesses on a first-come, first-serve basis.

In this piece, I'd like to demystify what's going on with the CARES Act. What do small business owners need to know and do right now, which parts of this package apply to them and which don't, and which elements of the act are we still seeking more clarity?

This money is going to go quick, so to give you a jump start, let's first look at the program that will apply to the largest swath of small business owners: the Paycheck Protection Program. From there, we'll look at three other programs that are worth your attention.

Publisher: Forbes
Date: 2020-04-14
Author: Garrett Gunderson
Twitter: @forbes
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Anti-Hybrid Rules: The IRS Issues Final & Proposed Regulations | Weil, Gotshal & Manges LLP -

The Tax Cuts and Jobs Act introduced two "anti-hybrid" rules that generally deny U.S. tax deductions in certain situations involving entities and payments of interest, royalties, or dividends, if such entities or payments are treated differently under U.S. and foreign tax laws and such different treatment results in double non-taxation. These two rules are found in Sections 245A(e) and 267A.

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Generally, Section 245A provides a participation exemption for certain domestic corporations that are shareholders of a foreign corporation. Specifically, Section 245A(a) provides a 100-percent dividends received deduction to domestic corporate shareholders for foreign-source dividends received from a 10-percent owned foreign corporation.

Publisher: JD Supra
Author: co author Charlie Roarty The Tax Cuts and Jobs Act introduced two anti hybrid rules that generally deny U S tax deductions in certain situations involving entities
Twitter: @jdsupra
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West Virginia Tax Department Adopts Regulations on Special Valuation of Wireless Communications

The West Virginia State Tax Department April 10 adopted regulations on the use of a special valuation method for the Tax Commissioner and the Board of Public Works to determine the assessed value of wireless communications transmission towers for property tax purposes.

Twitter: @tax
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Businesses Urged to Prepare for Post-Coronavirus Compliance Surge (1)

Remote sellers coping with overdue liabilities or lingering audits should use the coming weeks to resolve their disputes with state revenue agencies and avoid a possible post-coronavirus compliance surge.

State revenue departments have responded to the public health crisis by extending tax filing and payment deadlines, and pulling back on new audits. In this forgiving climate, remote retailers affected by tax laws inspired by the Supreme Court's 2018 South Dakota v. Wayfair ruling may want to quickly remedy past tax problems, said Alex Thacher, a state and local tax partner in the San Jose office of the tax consulting firm Armanino.

Twitter: @tax
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Rise of the (fax) machines - POLITICO

— The IRS is turning to fax machines to cope with office closures spurred by the coronavirus outbreak.

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— The agency also has good news for cash-strapped businesses, Opportunity Zones and those concerned about completing so called like-kind exchanges.

— Roughly 80 million economic stimulus payments are on their way to Americans' bank accounts — but questions remain.

IT'S TUESDAY, though, really, who can even tell anymore? Every day is Groundhog Day when you're in quarantine.

Publisher: POLITICO
Twitter: @politico
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