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Date Title
July & August 2014
Newsletter
This is the July & August 2014 edition of China Tax Monthly.
July 2014
Client/Legal Alert
The Tax Administration Service (SAT) has now published the Second Amendment of the Miscellaneous Tax Rules for 2014, containing rules defining the types of income that companies with maquila operations may continue to generate without jeopardizing the statutory protection of their foreign principal from a permanent establishment exposure in Mexico.
July 2014
Newsletter
This is the July 2014 issue of the European Tax Newsletter.
July 2014
Client/Legal Alert
The tax reform effective in 2014 includes a new obligation requiring the monthly filing of accounting information on electronic media pursuant to the general rules.
July 2014
Client/Legal Alert
The Ministry of Finance amended the General Rules referred to in the Federal Law for the prevention and identification of transactions with funds from illegal sources and the official formats used to file for registration and to file monthly notices.
August 2014
Client/Legal Alert
The Organisation for Economic Cooperation and Development released the Standard for Automatic Exchange of Financial Account Information in Tax Matters in July 2014 to combat offshore tax evasion, which is a serious problem for countries around the globe. The new rules will make it easier for governments to track down untaxed money placed in offshore accounts.
August 2014
Client/Legal Alert
On 11 August 2014, the Federal Official Gazette published the Decree issuing the Hydrocarbons Revenue Law (the LISH for its acronym in Spanish), which was submitted by the President together with a number of projects to amend, add, and repeal several provisions of the Federal Law on Fees and the Fiscal Coordination Law, which were submitted to the Congress within a package of secondary legislation derived from the recent constitutional reforms in energy matters.
May 2014
Client/Legal Alert
At a recent open hearing of the Budget and Taxes Committee of the lower chamber of the Russian Parliament the Minister of Finance confirmed ongoing work on legislative implementation of a beneficial owner requirement. Ahead of this announcement the Russian Ministry of Finance issued a new letter outlining the beneficial ownership concept for withholding tax purposes, discussing common back-to-back arrangements.
July 2014
Client/Legal Alert
On 21 July 2014 Russia adopted a law that, subject to certain limited exceptions, requires all companies that collect and process personal data of Russian citizens to use databases located in Russia. Non-compliance with these rules may result in a company’s website being blocked for Russian users. The new rules will become effective 1 September 2016.
18 June 2014
Client/Legal Alert
The European Court of Justice just ruled, in a decision of 12 June 2014 (ECJ case C-40/13), that the Dutch tax consolidation regime which forbids to include in a tax group two Dutch resident sister companies held by a common parent entity residing in another EU Member State that does not have a permanent establishment in the Netherlands, constitutes a restriction to the freedom of establishment.
26 May 2014
Client/Legal Alert
It is reminded that the French tax authorities can ground reassessments related to trademark’s royalties in the only extent that they can demonstrate, based on relevant comparables, their economic approach.
June 2014
Newsletter

In this Issue:

  • David R. Tillinghast - Lawyer, Teacher, Statesman, Legend, Retires From Baker & McKenzie
  • Treasury Alters Landscape for Triangular Reorganizations - Again Addressing Killer B Transactions
  • Eliminating Electivity: Proposed Regulations Redefine "Acquiring Corporation" to Eliminate a Tax Attribution Succession Option
  • IRS Applies Section 956 Anti-Abuse Rule to Loan Funded Through a Partnership with CFC Partners
  • Notice Provides Transition Period for FATCA Enforcement and Announces Rule Changes
  • New York District Court Denies Work Product Protection to Planning Documents Assessing Tax Litigation Hazards
  • Businesses Need to Resolve Tax Issues Only with Tax Authorities and Not With Class Action Plaintiff Attorneys - The Loeffler Case
  • Standing on the Verge of New York Franchise Tax Reform
  • New York State Brings Significant Changes to Tax Laws Affecting Estates and Trusts
  • Time to Play Quash: Tenth Circuit Creates Circuit Split in Finding Procedural Defects Fatal to IRS Summonses
  • Provisional Measure No. 627/13 is Converted into Law
  • Global Transfer Pricing Practitioners to Present Full-Day Workshop This July in Santa Clara, California 
  •  First Annual Baker & McKenzie / Bloomberg BNA Canada Transfer Pricing Conference to be held September 29-30 in Toronto, Ontario
June 2014
Client/Legal Alert
Starting from 4 August 2014 Russian citizens will be required to notify the authorities about acquisition of a foreign citizenship or the right to permanently reside in a foreign state.
June 2014
Client/Legal Alert
On 18 June 2014, the US Internal Revenue Service (IRS) announced changes to the 2012 Offshore Voluntary Disclosure Program (OVDP) and the Non-Resident US Taxpayer Disclosure Program (now referred to as the Streamlined Filing Compliance Procedures). The changes are intended to ease burdens and help taxpayers come into compliance by extending the eligibility requirements for the Streamlined Filing Compliance Procedures to a wider population of US taxpayers living outside of the United States, as well as to certain US taxpayers residing in the United States.
May 2014
Client/Legal Alert
The 34 member countries of the OECD, including Mexico, as well as Argentina, Brazil, China, Colombia , Costa Rica, India, Indonesia, Latvia, Lithuania, Malaysia, Saudi Arabia, Singapore, and South Africa adopted the Declaration on the Automatic Exchange of Information on Tax Matter (hereinafter the Declaration) on 6 May 2014.
 
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