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Article

Fox Rothschild LLP | USA | 21 Jan 2013

Service prevails before Tax Court in self-employment tax case

In a recent memorandum decision of the Tax Court in Howell, TCM 2012-303, a couple was held liable for a deficiency in self-employment taxes, plus

Article

Fox Rothschild LLP | USA | 3 Jan 2013

Congress and President Obama sign into law the American Taxpayer Relief Act of 2012

On January 1, the Senate, by a vote of 89-8, passed H.R. 8, the "American Taxpayer Relief Act of 2012" ("ATRA"). ATRA was then rushed to the House of

Article

Fox Rothschild LLP | USA, Canada | 6 Dec 2012

U.S. and multi-national companies engaged in Canadian business operations through controlled Canadian subsidiaries need to stand on guard for possible legislation on interest stripping and other rules

Many U.S. companies engage in business operations in foreign countries, including Canada, through the use of a controlled or wholly owned subsidiary

Article

Fox Rothschild LLP | Cuba | 3 Dec 2012

Cuba: cigars, mojitos, and income taxes?

One generally associates Cuba with premier cigars, mojitos, and Fidel Castro. Income taxes, on the other hand, are probably not something most would

Article

Fox Rothschild LLP | USA | 19 Nov 2012

Capital gains and dividend income tax rates scheduled to increase in 2013: Added Impact of New Medicare Contribution Tax

Unless Congress can act decisively before the end of this year, the marginal federal income tax rates will increase for taxable years beginning on or after January 1, 2013.

Article

Fox Rothschild LLP | India | 26 Jun 2012

UK telecommunications company Vodafone recently receives favorable ruling from Supreme Court of India

This past January, the Supreme Court in India ruled in Vodafone International Holdings B.V v. Union of India,Civil Appeal No. 733 of 2012 (arising from S.L.P. (C) No. 26529 of 2010) that the sale of stock of a company that was non-resident in India to another non-resident company was not subject to income tax in India.

Article

Fox Rothschild LLP | USA | 21 Dec 2011

Suburban employers beware: new requirements for local earned income tax under Act 32 of 2008 take effect Jan. 1

Act 32 of 2008, a law that reforms and standardizes the local earned income tax (EIT) system, carries new requirements for administering local taxes, uniform withholding and remittance of the tax that go into effect Jan. 1, 2012.

Article

Fox Rothschild LLP | USA | 16 Dec 2011

IRS issues fact sheet providing information on federal income tax return and foreign bank filing requirements

The federal government has known for some time that taxpayers who are dual citizens or dual residents of the United States and another country may have knowingly or innocently failed to timely file U.S. federal income tax returns.

Article

Fox Rothschild LLP | USA | 6 Dec 2011

Tax Court rules on non-resident, professional golfer's treatment of U.S. source royalty and personal service income in Goosen v. Commissioner

Non-residents of the U.S. are subject to U.S. income tax on U.S. source fixed and determinable annual or periodic income, as described in Section 871(a), which income, subject to treaty override, is subject to a flat 30 tax rate without deductions.

Article

Fox Rothschild LLP | USA, Canada | 8 Nov 2011

New technical interpretation issued by Canada Revenue Agency on stock options will spark debate

A recent technical interpretation issued by the Canada Revenue Agency, Technical Interpretation 2011-0393411E5, provides that under Article XV of the Canada-U.S. Income Tax Convention, that after 2008, when a U.S. resident employee of a Canadian resident corporation acquires shares of the corporation on the exercise of employee stock options, the Canada Revenue Agency (CRA) would disallow that the income from the taxable amount would qualify for exemption from Canadian income tax under the Canada-U.S. Tax Treaty, even if the employer was not present in Canada for more than 183 days.

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