Thursday, December 3, 2020

Supreme Court Justices Question IRS Shield in Tax-Shelter Case - WSJ

Supreme Court Justices Question IRS Shield in Tax-Shelter Case - WSJ

WASHINGTON—Supreme Court justices sharply questioned arguments by the federal government that certain tax regulations can't be challenged in court before they are enforced.

Justices across the ideological spectrum, including Samuel Alito, Stephen Breyer, Elena Kagan and Neil Gorsuch, expressed skepticism about the government's position during an hour-long oral argument Tuesday. A ruling against the government would make it harder for the Internal Revenue Service to demand and collect information that it uses to police tax shelters and could invite more-frequent legal challenges.

Publisher: WSJ
Date: 2020-12-01T22:43:00.000Z
Author: Richard Rubin and Brent Kendall
Twitter: @WSJ
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In case you are keeping track:

Breaking the "Equity Wall": Proposed Regulations Limit Chances to Minimize U.S.

The discussion below first presents a brief overview of the 30 percent withholding tax as well as the "anti-conduit" rules, then describes the key changes that the Proposed Regulations would make.

The U.S. federal income tax law imposes a 30 percent tax on a foreign person's U.S. source "fixed or determinable, annual or periodical income" (such as interest, dividends, rents, royalties and similar types of income). This tax is imposed on gross income, with no deductions allowed. In general, this tax is collected by means of withholding, and it is therefore commonly referred to as the 30 percent "withholding tax.

Publisher: JD Supra
Twitter: @jdsupra
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Africa tax in brief - Lexology

Once the application is submitted, the tax administration is obliged to respond and notify the applicant within a maximum of 75 days. However, an urgent response within 45 days may be provided for justified requests, provided that the request is accompanied by a legal-tax framework proposal. The tax authority must notify an applicant within 30 days on whether a request is accepted as urgent.

Once issued, a ruling is binding on the tax administration and may not be deviated from, except in compliance with a judicial decision. The term of validity of a binding ruling must be indicated by the tax administration at the time of issuance. A binding ruling may expire, however, if there are subsequent changes in the factual or legal assumption on which the ruling is based.

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Implementing the Law on Tax Administration: Decree 126

Vietnam introduced Decree 126/2020/ND-CP (Decree 126) guiding the implementation of the Law on Tax Administration 2019, which took effect in July 2020.

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As described in our previous article on tax administration, the regulations allow tax authorities additional power to collect tax, particularly in instances where individuals or companies attempt to evade tax.

As per the new regulations tax authorities are likely to apply the substance over form approach. The substance over form concept is where financial statements reflect accounting transactions rather than a simple legal form. This concept shows the overall financial health of the business.

Publisher: Vietnam Briefing News
Date: 2020-12-02T07:00:15 00:00
Twitter: @VietnamBriefing
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Not to change the topic here:

The Double Taxation Dispute Resolution (EU) (Revocation) (EU Exit) Regulations 2020 -

The existing Regulations were introduced for the implementation of Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolutions in the European Union (the Directive). The scope of the Directive is limited to member states of the EU. The United Kingdom is no longer a member state of the EU and will cease to be within scope of the Directive following the end of the transition period.

Publisher: GOV.UK
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Farmer sentiment pulls back post-election; regulation, trade, and taxes rated as top concerns

WEST LAFAYETTE, Ind., and CHICAGO — The Purdue University/CME Group Ag Economy Barometer dropped 16 points to a reading of 167 in November, down from its all-time high set just one month ago. The decrease in sentiment was led by farmers’ more pessimistic view toward the future of the agricultural economy, with the Index of Future Expectations falling 30 points to a reading of 156 in November.

The Ag Economy Barometer is calculated each month from 400 U.S. agricultural producers’ responses in a telephone survey. This month’s survey was conducted Nov. 9-13, after the U.S. election.

Author: Purdue Marketing Media Purdue University
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PIMCO Energy and Tactical Credit Opportunities Fund Declares Quarterly Common Share

NEW YORK, Dec. 02, 2020 (GLOBE NEWSWIRE) -- The Board of Trustees of PIMCO Energy and Tactical Credit Opportunities Fund (the "Fund") (NYSE: NRGX) declared a quarterly distribution for the Fund on December 1, 2020. The quarterly distribution is payable on January 4, 2021 to shareholders of record on December 11, 2020, with an ex-dividend date of December 10, 2020.

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Distributions may include ordinary income, net capital gains and/or returns of capital. Generally, a return of capital occurs when the amount distributed by the Fund includes a portion of (or is comprised entirely of) your investment in the Fund in addition to (or rather than) your pro-rata portion of the Fund's net income or capital gains.

Publisher: GlobeNewswire News Room
Date: 12/2/2020 9:46:27 PM
Author: PIMCO Account Management
Twitter: @globenewswire
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Michigan Approves Regulations for Mobile Gaming and Sports Betting

The Michigan Joint Committee on Administrative Rules (JCAR) voted yesterday to waive a 15-day waiting period to approve proposed state regulations. The decision expedites the process to commence online gambling and begin generating much-needed tax revenue for the state and City of Detroit.

JRAC approved the regulations set forth by the Michigan Gaming Control Board (MGCB) and tax rates imposed by state lawmakers. The MGCB can now proceed in fielding mobile sports betting and iGaming applications from casinos, both commercial and tribal.

Author: Devin O
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