Meet the Co-chairs - TAGLAW
Williams Mullen (VA)
Meet the Co-chairs - TIAG
Mercer & Hole
Cohen & Company (Ohio)
Fineman West & Co. LLP
Contact: Boodle Hatfield (London, England)
As reported in our last edition, some fundamental changes to the taxation of 'non-doms' (UK residents who are domiciled abroad) are due to take effect from April 2017. A Consultation was issued at the end of September on the details of two of the three proposals. We await HMRC's response and detailed draft legislation. Meanwhile, however, some limited draft legislation has been published on the IHT changes.
BY: ROBERT B. HAMLETT, JR.
On December 18, 2015, the President signed into law the Protecting Americans from Tax Hikes Act of 2015, HR 2029, PL 114-113 (the “PATH Act”), which extends or makes permanent over fifty (50) expiring tax provisions relating to businesses and individuals.
This Alert provides an overview of several important tax provisions affecting businesses and individuals contained in the PATH Act. Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Prior results do not guarantee a similar outcome. You should consult your own tax advisor regarding the United States federal, state, local, non-U.S. and other tax consequences of the provisions of the PATH Act.
Click here to continue reading.
Contact: Voisin (Isle of Man)
Jersey’s Taxes Office has reached an agreement with the UK tax authorities at HM Revenue and Customs (‘HMRC’) on the interpretation of the residence of companies under the 1952 Jersey - UK Double Taxation Agreement (‘DTA’).
Utilising the mutual agreement provisions contained in the DTA, it has been agreed that paragraph 2(1)(f) of the DTA should be considered as a residence tie-breaker test for companies which are regarded as resident in both jurisdictions under their relevant domestic tax rules.
Tax crimes may be defined, in short, as economic crimes perpetrated against the “public treasury.” Through the commission of a criminal act, the interest of the public treasury, in a wider sense, the interest of the general public is violated. The aim of the penalty is, therefore, the timely payment of taxes due. The principles pertaining to tax crimes and penalties are regulated under the Tax Procedure Code (“TPC”). Some of the crimes and penalties stipulated under the TPC solely concern the tax law, and tax offices can directly apply these penalties without further need of a judicial decision. The acts within this scope are evaluated as “financial crimes and penalties.” On the other hand, other crimes and penalties regulated under the TPC are crimes according to criminal law, and are punishable by restricting freedom. These are determined as “criminal crimes and penalties”.
Administrative Ruling SNAT/2015/0021, issued by the Superintendent of the National Integrated Service of Customs and Tax Administration (Servicio Nacional Integrado de Administración Aduanera y Tributaria – “SENIAT”), was published in Official Gazette No. 40,744 of September 11, 2015. Said Ruling established the rules for the accounting adjustment of taxpayers that perform banking, financial, insurance and reinsurance activities, excluded from the adjustment-for-inflation system.