Sunday, March 21, 2021

Transfer Pricing in Vietnam—New Regulatory Environment

Nguyen Dinh Du and Do Vu Bao Khanh of Grant Thornton Vietnam explain the new regulations introduced recently in Vietnam updating the national transfer pricing regime, and consider the resulting benefits and challenges of these measures for taxpayers.

Transfer pricing (TP) has been considered a significant issue in tax audits in Vietnam in recent years. Many multinational enterprises with subsidiaries operating in Vietnam have fallen under the scrutiny of the Vietnamese tax authorities, indicated by the fact that TP-compliant documents have become one of the first pieces of information required in many tax audits.

Twitter: @tax
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Many things are taking place:

WEEKEND INSIGHTS: Nothing Is a Slam Dunk When It Comes To Tax

While many tax practitioners are focused on tax season, others may be focused on a different one: tournament season.

The NCAA Division I men's basketball tournament, played annually since 1939, tipped off this week. The occasional Cinderella story has made the tournament a must-watch in March as 68 teams—including some that you may not know—compete in seven rounds for the national championship.

The NCAA Division I women's basketball tournament, played annually since 1982, begins on Sunday, March 21. The tournament features 64 teams vying for the national title.

Twitter: @tax
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Third stimulus check rules for dependents: Eligibility, more money, tax breaks - CNET

In terms of federal tax regulations, a dependent falls into two categories: a qualifying child or a qualifying relative. They don't need to be children, or directly related to you, but they do have to meet certain requirements set out by the IRS.

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One situation that cropped up with the first check are parents who aren't married and have joint custody and alternate years in which they claim each dependent child (or children) on their tax returns. In that case, both parents were eligible under the first two stimulus bills to receive the $500 per qualifying child for the first check and $600 for the second.

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Publisher: CNET
Author: Alison DeNisco Rayome
Twitter: @CNET
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Sanders proposes tax for 'absurd' CEO pay as Dems target income inequality | KATV
Publisher: KATV
Date: 2021-03-18T16:55:56 00:00
Author: Stephen Loiaconi
Twitter: @KATVNews
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In case you are keeping track:

ARPA Prohibits State Actions that may Use Federal Funds to Offset Tax Reduction

On March 11, 2021, US President Joe Biden signed the American Rescue Plan Act of 2021 (ARPA), the COVID-19 relief bill that includes $350 billion in relief to states and localities. To prevent states from using federal relief funds to finance tax cuts, Congress included a clawback provision requiring that any relief funds used to offset tax cuts during the next three years be returned to the federal government. Here is the text of the provision:

A State or territory shall not use the funds provided under this section or transferred pursuant to section 603(c)(4) to either directly or indirectly offset a reduction in the net tax revenue of such State or territory resulting from a change in law, regulation or administrative interpretation during the covered period that reduces any tax (by providing for a reduction in a rate, a rebate, a deduction, a credit or otherwise) or delays the imposition of any tax or tax increase.

Publisher: The National Law Review
Date: 5493B547C0AB527FF4CF8C4D0127302A
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Matters of 608 Franklin, LLC and Evergreen Gardens, LLC; Division's Rep.

We lumped these two cases together because they present pretty much identical facts, legal issues, and outcomes. Indeed, the opinion sections of each decision contain virtually identical structure and language. You can read our full recaps of both ALJ Determinations here and here . The issue in these cases was whether security services provided at real property construction projects were taxable.

This should be an easy question, right? Wrong. It actually requires a rather nuanced analysis of two statutory provisions that seem diametrically opposed. Tax Law § 1105(c)(8) imposes sales tax upon security services of every nature. However, Tax Law § 1105(c)(5) exempts services to real property in capital improvement projects. So what happens when otherwise taxable security services are performed at a capital improvement job site? Which provision wins?

Publisher: JD Supra
Twitter: @jdsupra
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VIDEO: Carr Pushes Back Against Attempted Federal Takeover of State Tax Policy - AllOnGeorgia

Carr appeared on CNBC's “Squawk Box” to discuss how he is working to ensure President Biden's American Rescue Plan Act does not commandeer Georgia's ability to cut taxes.

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Certain provisions of the Act forbid states from using COVID-19 relief funds to "directly or indirectly offset a reduction in…net tax revenues" resulting from state laws or regulations that reduce tax burdens, whether by cutting rates or by giving rebates, deductions, credits, "or otherwise."

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Publisher: AllOnGeorgia
Date: 2021-03-19T21:25:54 00:00
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MD Digital Advertising Tax Bill

The Maryland tax also reflects the collision of two economic forces magnified by the pandemic: While cities and states have seen their tax revenues plummet as the need for government-provided social services has skyrocketed, the tech giants have reaped landmark profits as social distancing has pushed work, leisure activities and commerce to online platforms in levels never before seen.

The tax applies to annual gross revenues derived by large firms from digital advertising services in the state. Excluded from the tax are entities with less than $100 million in global annual gross revenue. From there, the tax rate increases based on the global annual gross revenues of the entity:

Publisher: The National Law Review
Date: 5493B547C0AB527FF4CF8C4D0127302A
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