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Updated: 4 hours 58 min ago

International Tax Alert - July 2014

Fri, 07/25/2014 - 12:00am
A longstanding Brazilian tax issue that has existed for more than a decade, with respect to the application of the business profits clause ("Article 7") of Income Tax Treaties (also known as Double Taxation Treaties or "DTTs"), has evolved in a positive direction. For more than a decade, the Brazilian tax agency ("RFB") applied a literal interpretation of the definition of business profits under Article 7 of DTTs.  The RFB took a narrow position on the application of Article 7 of DTTs relating to net profits generated by a non-Brazilian person.  Applying this narrow position, the RFB determined that a non-Brazilian person's items of gross income should not be covered by Article 7. 
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International Tax Alert - July 2014

Fri, 07/25/2014 - 12:00am

Brazil: Treaty Interpretation

International Tax Alert - July 2014

Fri, 07/25/2014 - 12:00am

Brazil: Treaty Interpretation

BDO Transfer Pricing News - July 2014

Tue, 07/22/2014 - 12:00am

This issue of Transfer Pricing News focuses on recent developments in the field of transfer pricing in Kuwait, the Netherlands and Switzerland. It also includes an interesting article on country-by-country reporting and a piece from BDO Belgium about a conflict of interest between transfer pricing and customs.

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International Tax Newsletter - July 2014

Tue, 07/15/2014 - 12:00am

BDO India has issued their monthly tax newsletter. July's edition covers case law highlights on direct and indirect taxes, includes a featured article on service tax and VAT in restaurants, and more.

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International Tax Newsletter - July 2014

Tue, 07/15/2014 - 12:00am

India Tax Newsletter

International Tax Newsletter - July 2014

Tue, 07/15/2014 - 12:00am

India Tax Newsletter

State and Local Tax Alert - July 2014

Thu, 07/10/2014 - 12:00am

On June 30, 2014, New Jersey Governor Chris Christie signed into law A. 3486, 216th Leg. (N.J. 2014) ("A. 3486"), which results in several significant tax changes, including changes to the  Corporation Business Tax ("CBT") laws as follows: (1) broaden the definition of operational income; (2) require a nonresident partner (corporate or noncorporate) to file a tax return in order to obtain a credit/refund of income tax paid on its behalf; and (3) reduce a net operating loss ("NOL") for debt discharged and excluded from income on account of bankruptcy or insolvency.  In addition, for sales and use tax purposes, the state has adopted a "click-through nexus" standard with respect to Internet sales activity.

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State and Local Tax Alert – July 2014

Thu, 07/10/2014 - 12:00am

New Jersey Enacts Significant Tax Changes

International Tax Newsletter - May 2014

Tue, 07/08/2014 - 12:00am

BDO China has issued a Tax Newsletter with updates on: new SAT-released standards for determining the beneficial owner under the entrusted investment, extension for applying for deferment of the export tax refund declaration, and more.

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International Tax Newsletter - May 2014

Tue, 07/08/2014 - 12:00am

China Tax Newsletter

State and Local Tax Alert - July 2014

Wed, 07/02/2014 - 12:00am

Over the past several months, many income tax developments have occurred in California, including the adoption of new and amended regulations, the release of several Chief Counsel Rulings and the Los Angeles Superior Court's March 6, 2014, bench ruling in In ComCon Prod. Servs. I Inc. v. Cal. Franchise Tax Bd., No. BC489779 (Cal. Super. Ct.), bench ruling ("Comcast").  These developments address some of the more important state income tax matters such as business vs. nonbusiness income, unitary relationships, apportionment, and sourcing of sales and could affect taxpayers across many industries and in various stages of the business life cycle.

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Compensation & Benefits Alert - July 2014

Wed, 07/02/2014 - 12:00am
The Service recently issued Rev. Rul. 2014-18,1  which clarifies that properly designed stock options and stock-settled stock appreciation rights ("SARs") are forms of deferred compensation that may be granted to service providers (including hedge fund managers) of certain hedge funds and entities that are based in foreign tax havens.  Such awards are exempt from section 457A, which generally precludes deferred compensation arrangements between these service providers and service recipients.
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BDO World Wide Tax News - July 2014

Wed, 07/02/2014 - 12:00am

BDO's summer edition of World Wide Tax News summarizes recent tax developments of international interest across the world, including Australia, Thailand and Malta.

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State and Local Tax Alert – July 2014

Wed, 07/02/2014 - 12:00am

Relevant California Income Tax Developments May Affect Taxpayers

State and Local Tax Alert – July 2014

Wed, 07/02/2014 - 12:00am

Limited Deferred Compensation Opportunities for Hedge Fund Managers Under Section 457A

BDO World Wide Tax News - July 2014

Wed, 07/02/2014 - 12:00am

Recent Tax Developments of International Interest across the World

BDO Indirect Tax News - July 2014

Tue, 07/01/2014 - 12:00am
The summer edition of BDO's Indirect Tax News features recent indirect tax developments in countries around the globe, including Germany, Latvia and New Zealand. Learn about a new VAT registration requirement in South Africa for foreign e-commerce businesses, the new VAT act in Ghana, and more.
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Expatriate Tax Newsletter - June 2014

Tue, 07/01/2014 - 12:00am
The Expatriate Newsletter tax updates provide a brief overview of issues affecting international assignees, predominantly, but not exclusively, from a tax and social security perspective. This newsletter brings together individual country updates over recent months.  As you will appreciate, the wealth of changes across multiple jurisdictions is significant so to provide easily digestible information we have kept it to the key developments that are likely to affect your business and international assignees. 
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Expatriate Tax Newsletter - June 2014

Tue, 07/01/2014 - 12:00am

Expatriate Tax Practice Updates

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