United States: IRS Announces That It Will No Longer Refund FICA Taxes On Severance Payments

The IRS recently announced that severance payments are taxable wages under FICA, and thus employers who seek tax refunds on those payments will be denied.  The IRS’s position reflects the United States Supreme Court’s ruling in United States v. Quality Stores, Inc., issued in March of last year.

Quality Stores, Inc. entered into bankruptcy proceedings in 2001 and terminated thousands of employees.  The company offered the employees a variety of severance plans depending on the […]

By |March 2nd, 2015|

United States: New York ALJ Determines Article 32 Taxpayer Not Required To Utilize NOL In Computing Tax Under Alternative Base

On January 22, an administrative law judge (ALJ) in the State of New York Division of Tax Appeals determined that a taxpayer subject to Article 32 (banking corporation franchise tax) was not required to apply a net operating loss (NOL) deduction to decrease its entire net income (ENI) in a tax year in which its ENI base was not the highest of the alternative bases for computing the tax.1 At this point, it is […]

By |February 27th, 2015|

Statement Of Brazilian Funds Located Overseas – CBE

According to Resolution No. 3.854 of 2010 published by the Brazilian Central Bank, individuals and legal entities resident, domiciled or headquartered in Brazil who possess an amount equal or greater than US$ 100,000.00 (one hundred thousand US Dollars) in assets and rights located overseas are obliged to present a Return to Brazilian Central Bank named “Declaração de Capitais Brasileiros no Exterior (CBE)”.

In accordance with Circular No. 3.624 of 2013 of Brazilian Central Bank, the […]

By |February 27th, 2015|