Tax & Accounting Blog

Open Transaction Doctrine does not apply in insurance company demutualization case.

Open Transaction Doctrine does not apply in insurance company demutualization case.

On July 9, 2012, a federal district court in Arizona ruled that the taxpayer could not apply the “open transaction” doctrine in a case involving stock received from an insurance company that demutualized. Background. A mutual insurance company has no shareholders.  Instead, the policyholders have an ownership interest in the company, in addition to having … Read More

NRA Withholding and Reporting on Payments to Foreign Nationals – Part 9: How Do I Find Out if the Payment Is U.S. Source Income?

NRA Withholding and Reporting on Payments to Foreign Nationals – Part 9: How Do I Find Out if the Payment Is U.S. Source Income?

The source of income is determined under U.S. tax rules based on the type of income. Compensation for personal services, whether employment or self-employment, is generally sourced where the services are performed, not where the income is paid. Therefore: Income for services performed outside the U.S. is foreign source income and is not subject to … Read More

Final Regs Clarify Economic Effect Requirement for Estate and Trust Donations

Final Regs Clarify Economic Effect Requirement for Estate and Trust Donations

On April 13, 2012, the IRS issued final regs providing guidance under Code Sec. 642(c) with regard to the federal tax consequences of an ordering provision in a trust, will or local law that attempts to determine the tax character of the amounts paid to a charitable beneficiary. Specifically, the regs confirm that a provision in a … Read More

France – Second Amending Finance Law for 2012 adopted by Council of Ministers

France – Second Amending Finance Law for 2012 adopted by Council of Ministers

Legislation is currently being discussed by the French Parliament that would reverse the previously planned VAT rise. The Second Amending Finance Bill for 2012, which was adopted by the Council of Ministers on 4 July 2012, is scheduled for parliamentary discussion on 16 July 2012. If the Bill passes, the previously planned increase of the standard VAT … Read More

Bangladesh: Trophies for Top Taxpayers

Bangladesh: Trophies for Top Taxpayers

Blog, Indirect Tax July 13, 2012

To kick off its second annual VAT Week (July 10-16th) the government of Bangladesh recognized the top 134 VAT paying companies at a ceremony on July 10th. Finance Minister AMA Muhith personally handed the awards to nine national-level recipients along with 27 from the greater Dhaka region, at a ceremony at Bangabandhu International Conference Centre. … Read More