Tax & Accounting Blog

IRS Postpones Information Reporting by Domestic Entities for Specified Foreign Financial Assets

On January 23, 2013, the IRS issued Notice 2013-10. The Notice postpones the date that domestic entities, including trusts, will be required to report their interests in specified foreign financial assets on Form 8938. Background Code § 6038D was enacted by section 511 of the Hiring Incentives to Restore Employment Act (the … Read More

Regulations Require Updating of Employer Identification Numbers

Regulations Require Updating of Employer Identification Numbers

On May 3, 2013, the IRS issued final regulations that require any person assigned an employer identification number (EIN) to provide updated information to the IRS in the manner and frequency prescribed by forms, instructions, or other appropriate guidance.  These regulations affect persons with EINs and will enhance the IRS’s ability to maintain … Read More

New Canadian Withholding Tax Documentation Requirements

New Canadian Withholding Tax Documentation Requirements

The Canada Revenue Agency (CRA) has changed its procedures for determining whether non-residents can claim a reduced rate of withholding tax under a tax treaty. Background Canada imposes a 25% withholding tax on certain types of Canadian source income paid to nonresidents of Canada.  Residents of countries with which Canada has a treaty may be … Read More

Federal district court in Arizona issues final decision in demutualization case

Federal district court in Arizona issues final decision in demutualization case

On April 19, 2013, the federal district court in Arizona issued a final decision in the Dorrance case.  2013 WL 1704907.  This follows a preliminary decision in July, 2012.  See our previous bulletin, “Open Transaction Doctrine does not apply in insurance company demutualization case,” July 16, 2012. Background: A mutual insurance company has no … Read More

onesource

Thomson Reuters ONESOURCE named Americas Tax Innovator of the Year

Last week, International Tax Review recognized Thomson Reuters ONESOURCE platform as Americas Tax Innovator of the Year at its seventh annual Americas Awards ceremony in New York. When asked why Thomson Reuters ONESOURCE was singled out for the award, Ralph Cunningham, managing editor of International Tax Review, said: “It is down to the impact … Read More

New French Law on the Taxation of Trusts

New French Law on the Taxation of Trusts

On July 29, 2011, France enacted a new law on the taxation of trusts. Under the new law, a trustee must disclose certain information about the trust if the trust has a French settlor, beneficiary or French assets. The trustee must file the disclosure by June 15. The government was to provide further details on how to … Read More