The international tax professionals at Cherry, Bekaert & Holland recently posted a brief individuals guide to Afghanistan income tax law.
It is recommended that government contractors performing work within Afghanistan consult legal and/or tax council to determine if they are covered as an “administrative and technical staff,” allowing them to be exempt from certain Afghanistan taxes.
The U.S. Department of the Treasury announced today a new income tax treaty between the United States of America and the Republic of Hungary.
In a ceremony held at the Hungarian Ministry of Finance in Budapest, Ambassador Eleni Tsakopoulos Kounalakis and Hungarian Finance Minister Péter Oszkó signed a new tax treaty that brings the existing agreement between the countries signed in 1979, into closer conformity with current U.S. tax treaty policy.
The new treaty contains a comprehensive limitation on benefits provision that is consistent with many recently concluded U.S. tax treaties and ensures that only residents of the United States and Hungary may enjoy the benefits of the treaty.
HM Treasury released the 2009 Pre-Budget Report. In his accompanying statement to the House of Commons, Chancellor of the Exchequer Alistair Darling announced his continued focus on preserving tax revenues. Businesses operating in the UK should expect little tax relief when the final budget is released.
Darling gave credit to government action for staving off what might have been an even worse fiscal year for the UK. Consumer inflation, expected to peak in 2010 at three percent, is expected to drop back down to a pre-recession level of 1.5 percent toward the end of the 2011. Broad economic growth is expected to return in most sectors toward the end of 2010.
Most relief programs will be focused at the consumer level, including the cash for clunkers inspired boiler scrappage scheme. Little action is taken to benefit businesses, and many tax reduction measures taken in the past several years will be allowed to lapse in 2010.
CB&H’s International Tax practice recently added a series of quick reference pdfs that summarize various types of tax treaties and agreements currently in force, awaiting final action, under negotiation, or terminated. You can access each of these pdfs below:
CB&H has updated the “Doing Business In…” page to now include the following updated Baker Tilly International pdf guides:
Click here to view the full list of available guides in the “Doing Business In…” series.
The National Automated Clearing House Association (NACHA), which oversees the ACH network, recently announced new compliance regulations for direct deposit transactions dealing with international parties. New International ACH Transactions (IAT) rules will now apply to certain direct deposit transactions.
These new rules subject all IAT transactions to screening from the Office of Foreign Assets Control (OFAC). The rules will track the identities of the originator, receiver and any financial institutions involved with an IAT direct deposit, much like current domestic wire transfer screens.
Cherry, Bekaert & Holland, L.L.P. (CB&H) is pleased to announce that Bill Elliot, Firm Director of International Tax, will be participating in the Knowledge Congress webcast entitled: “Understanding the IRS New Contract Manufacturing Rules” on February 23, 2010 from 12:00 pm until 2:00 pm.
The Treasury and the IRS are in the process of finalizing the laws concerning contract manufacturing arrangements as per the anti-deferral regime Subpart F. Set to take effect for tax years of foreign controlled companies beginning after June 30th, 2009, the new guidance aims to update and modernize the contract manufacturing regs under Subpart F. While the Regs are generally well received by taxpayers, there is much confusion surrounding key areas such as: retention of the fundamental approach, clarification of personal property sale issues, and turnkey CFCs to name a few.
CB&H presented the webinar “International Tax Trends and Challenges” on Thursday, November 18, 2009. Led by Bill Elliott, the webinar reviewed the fundamentals of U.S. transfer pricing in the context of international transactions between affiliates, and the six basic principles of U.S. Transfer Pricing embodied in Section 482 of the Internal Revenue Code.
For any additional information on the range of international services offered by CB&H, please contact Bill Elliott.
A third arrest and conviction was made last week in the continuing government campaign against foreign tax evasion. Bloomberg reports on the circumstances surrounding what is likely only the latest person to be brought to justice for filing false tax returns.
Robert Moran, a Florida yacht broker who pleaded guilty to hiding $3.4 million in assets at UBS AG, was sentenced today to two months in prison after cooperating with prosecutors investigating offshore tax evasion.
Congressman Charles Rangel (D-NY), Chairman of the House Committee on Ways and Means, recently introduced the Foreign Account Tax Compliance Act of 2009. The bill would serve as a comprehensive clamp down on individuals seeking to avoid taxes through the use of offshore banks. The Joint Committee on Taxation (JCT) estimates this action will recoup $8.5 billion in U.S. tax over the next 10 years.
“Shortly after taking office, I laid out a set of proposals to crack down on illegal overseas tax evasion,” President Obama said in a statement supporting the legislation. “I look forward to working with Congress to turn these proposals into law so that honest Americans no longer shoulder the burden of the few individuals and businesses that put profit before responsibility.”
