IRS Announces Regulations Identifying Two New Foreign Tax Credit Splitter Arrangements

The IRS has announced forthcoming regulations (Notice 2016-52) under Section 909 dealing with foreign tax credits after a foreign adjustment.

The guidance will identify two new foreign tax credit splitter arrangements relating to certain foreign corporations that pay foreign income taxes pursuant to “foreign-initiated adjustments.” In the notice, the IRS stated it is aware certain taxpayers may take steps to separate the anticipated tax payments resulting from foreign-initiated adjustments from the related income. Foreign-initiated adjustments […]

By |November 17th, 2016|

Tax Reality Of Real Estate Trusts in India

When the new government took over and assumed the office, it was anticipated that many path breaking decisions would be taken. Keeping the optimistic sentiments alive, the Honourable Finance Minister, while presenting the budget for the fiscal year 2014 – 15 introduced a long-awaited concept of retail funding in the real estate sector by way of introducing Real Estate Investment Trust (“REIT”) and Infrastructure Investment Trust (“Invit”) (collectively referred to as Business Trust). Accordingly, […]

By |November 15th, 2016|

The Complexities Of Brazilian Service Tax

Despite reforms at a national level aiming to correct structural distortions in Brazil’s Service Tax (ISS), it remains complex even for experienced local entrepreneurs.

Brazil’s complex tax environment is confusing not only for foreign companies looking to invest in the country, but even for the most experienced Brazilian entrepreneurs.
Service Tax (ISS)
In the context of the Brazilian service tax (Imposto sobre Serviços or ISS) it’s not unusual to observe challenges like competition between tax collecting entities, […]

By |November 11th, 2016|