THIS ACRONYM STANDS for the International Financial Reporting Standards being the standards and interpretations adopted by the International Accounting Standards Board (IASB).
During February 2006 the FASB and the IASB concluded a memorandum of understanding stating their intention to seek a convergence of their standards and interpretations by 2008. Remember FIN 48 is a FASB standard.
The Internal Revenue Service has released the new 2014 Form W-8BEN-E (2-2014) that coincides with FATCA (Foreign Tax Compliance Act) and QI entity classification reporting requirements.
The newest version of Form W-8BEN-E must be used by entities that are beneficial owners of a payment, or of another entity that is the beneficial owner. The form has thirty parts, whereas the draft form only had twenty-seven. All filers will complete Parts I and XXIX.
Part I of the form requires general information, the QI status, and the FATCA classification of the filer. Question 4 of Part I requests the QI status. If the filer is a disregarded entity, partnership, simple trust, or grantor trust, then the filer must complete Part III if the entity is Read More
Report Concerning Advance Pricing Agreements (2013)
Highlights excerpted:
In February of 2012, the former APA Program was moved from the Office of Chief Counsel to the Office of Transfer Pricing Operations, Large Business and International Division of the IRS (TPO) and combined with the United States Competent Authority (USCA) staff responsible for transfer pricing cases, thereby forming the Advance Pricing and Mutual Agreement (APMA) Program. During the last quarter of 2013, new proposed revenue procedures governing APA applications and MAP applications were released for public comment in Notice 2013-79, 2013-50 I.R.B. 653, and Notice 2013-78, 2013-50 I.R.B. 633, Read More
We invited investors in to see the internal workings of TaxConnections this past week and they were very excited about what they saw behind the scenes. The question came up “How are you driving so much traffic to TaxConnections?” The answer is simple “A media site connecting a global audience searching for tax help to a world of tax advisors that were previously not easy to find was needed! After all, if you go to the search engines they will give you those tax professionals only in your area or those who have paid to be in the top spots. We give consumers worldwide easy access to a panoply (an impressive collection) of tax advisors with a wide range of experience in one click.” As a result, the traffic keeps coming to www.taxconnections.com.
The investors then asked “How did a tax professional in South Africa get a client in the U.K? Read More
THE FINANCIAL ACCOUNTING Standards Board (FASB ) on July 13, 2006, issued the final interpretation amending FASB Statement of Financial Accounting Standards No. 109, “Accounting for Income Taxes.” Of great importance was FASB Interpretation No. 48, “Accounting for Uncertainty in Income Taxes” (FIN 48. The purpose behind publishing the interpretations was to address the uncertainty in accounting for income tax assets and liabilities. FASB No. 109, in the past, contained no guidance on accounting for income tax assets and liabilities, resulting in businesses taking inconsistent positions. According to Read More
Reorganization is a transaction aspect of foreign corporate entry and exit activity that can have great importance in the considerations accompanying financial planning. To provide an adequate foundation to the fundamental understanding of reorganization considerations, a cursory overview of basic domestic, reorganization concepts is helpful.
These concepts can be divided into three types of reorganizing transactions. First, there are reorganizations deemed to be exiting the taxing jurisdiction of the United States. Second, reorganization transactions occur in the transnational process of the reorganization of a foreign corporation within a United States taxing jurisdiction. This would be a transaction Read More
One of the biggest problems envisaged with the MOSS systems is identifying the location of the customer.
It is essential for suppliers to correctly identify the customer’s location/permanent address/usual residence so they can charge the correct VAT rate applicable in that member state.
For most telecommunication, broadcasting and electronically supplied services, it will be obvious where the customer resides. The decision about the place of supply of those services should be supported by two pieces of non-contradictory evidence including credit card details and a billing address for example. Read More
♦ An estate & trusts lawyer was reading out the will of a rich man to the people mentioned in the will: “To you, my loving wife Rose, who stood by me in rough times, as well as good, I leave the house and two million.” The lawyer continued, “To my daughter Jessica, who looked after me in sickness and kept the business going, I leave the yacht, the business and one million.” The lawyer concluded, “And, to my cousin Dan, who hated me, argued with me, and thought that I would never mention him in my will well you are wrong. “Hi Dan!
♦ An accountant, a tax attorney and an actuary were dining together at a fashionable restaurant.
“With income tax being so complicated, we accountants are all doing quite well these days,” Read More
Foreign financial institutions (FFIs) and US withholding agents (USWAs) have presented compliance concerns to Treasury and the IRS about the status of FFIs in jurisdictions that are known to be in an advanced stage of concluding an IGA, but have not yet signed such agreement. Treasury has signed IGAs with 26 jurisdictions and has reached agreements in substance or is in advanced discussions with many others.
Treasury and the IRS have on April 2, 2014 issued Announcement 2014-17 to provide some level of comfort to FFIs in such jurisdictions that already have reached an IGA in substance and to USWAs paying agents.
Moreover, the IRS has also granted an extension of 10 (ten) days, previously April 25 but Read More
On April 3, 2014, The Senate Finance Committee agreed to expand the Federal-Level Research and Experimentation Tax Credit (hereinafter “RTC”) for certain small businesses, making the tax incentive available to companies that don’t have an income tax liability.
The change, pushed by Senator Chuck Schumer (D-N.Y.) and other lawmakers on the Hill, proposes to make the RTC available to many start-up companies that typically aren’t able to claim it during their first years in operation, as Senator Chuck Schumer indicated at the Finance Committee’s markup on expired tax incentives. Senators across both sides of aisles approved the proposal on a voice vote, with no objections.
Pursuant to the currently expired statute, companies can take the RTC only if they have Read More
What needs to be considered prior to the introduction of the MOSS Scheme on 1st January 2015 by businesses already established in Ireland or thinking about establishing in Ireland?
• It is essential to examine your contract to establish who exactly is paying you and if your customer is a taxable or non taxable person. This is particularly important in the context of undisclosed agents/commissionaire structures, etc.
• You must determine where your B2C customers are located. Your business may require additional contractual provisions and amendments to your systems to include this information.
• It is important to examine the impact of the different VAT rates in each E.U. member state Read More
The California Competes Tax Credit is an income or franchise tax credit available to businesses that come to California or stay and grow in California. Tax credit agreements will be negotiated by Governor’s Office of Business and Economic Development (GO-Biz) and approved by a newly created “California Competes Tax Credit Committee,” consisting of the State Treasurer, the Director of the Department of Finance, the Director of GO-Biz (Chair), and one appointee each by the Speaker of the Assembly and Senate Committee on Rules.
For fiscal year 2013/2014, applications for the California Competes Tax Credit will be accepted at calcompetes.ca.gov from March 19, 2014, until April 14, 2014. Go to business.ca.gov for more information on the California Competes Tax Credit. Read More
What Is Research & Development?
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