Search results for

Edward Tanenbaum On August 19 2009, the Internal Revenue Service (IRS) and the Justice Department announced that they had reached an agreement with international bank UBS regarding the IRS' John Doe summons to obtain approximately 4,450 names of US taxpayers with accounts in UBS. The Justice Department had filed a petition in February 2009 seeking enforcement of the John Doe summons served on UBS in July 2008 that had asked for the names of as many as 52,000 US taxpayers with undeclared accounts at the bank. The principal terms of the settlement agreement are as follows:

Sean Foley Landon McGrew The IRS recently issued new guidance providing extended relief for late check-the-box elections. Under revenue procedure 2009-41, the IRS has extended the time period for requesting relief for a late check-the-box election to three years and 75 days after the requested effective date of the entity classification election. The new rules also extend relief to changes in entity classification. Under the old rules, relief was only available for initial entity classifications.

Vladimir Kotenko The state tax administration (STAU) has opined that the salary received by a foreigner from a Ukrainian payroll is taxed at 15% only if such an individual has opted for Ukrainian tax residence status. In all other cases, Ukrainian-sourced income of non-residents (except for interest, dividends and royalty) should be taxed at 30%.

Ersun Bayraktaroglu Baran Akan Despite the turmoil in the global economy triggered by the mortgage crisis, real estate remains among the most popular investment areas around the world.

Carl Pihlgren In March 2009, the Swedish Supreme Administrative Court decided that the Swedish rules regarding group contributions (the Swedish tax consolidation system) in certain situations were incompatible with European Commission (EC) law. Based on this decision, the Swedish government has proposed new rules concerning so-called group deductions (deduction of losses in foreign subsidiaries).

Antonio Matute The Basque country (or more precisely, the Basque territories of Biscay, Alava and Guipuzcoa) and Navarra are the only Spanish regions which have powers to enact their own particular corporate income tax (CIT) regulations. Basque CIT regulations have many similarities with the CIT regulations applicable in the rest of Spain but also have some differences.

Suzanne Boers On Prinsjesdag (Dutch budget day), traditionally on the third Tuesday of September, the Dutch government presented its budget plans for 2010, including five Bills that make up the 2010 tax package. The Bills reflect the government's focus on stimulation and entrepreneurship. The essential points are: the stimulation of innovative entrepreneurship, boosting the cash flow for businesses with regard to the economic crisis, and the liberalisation of the participation exemption regime.

David Cuéllar José González An amending protocol to the August 3 1993 income tax treaty between Mexico and Switzerland was signed on September 18 2009.

Akio Takisaki On August 30, the Democratic Party of Japan (the opposition party) won a big election victory in the House of Representatives, the lower house of the Diet.

Nicolas Jacquot French business tax (taxe professionelle), which was created in 1976, is one of the four direct taxes collected by local councils. Any individual or legal entity engaged on a habitual basis in a no-salaried or professional activity is liable to this local tax, the rate of which is decided by local councils each year. The tax has two bases: the rental value of property, and equipment and movable assets, used for the needs of the business activity.