Background
In 2013, George Osborne announced in his Autumn Statement that a new capital gains tax (CGT) charge would be introduced from April 2015 in relation to non-UK residents who own UK residential property. A consultation paper was circulated in March, at the end of last month the Government published a summary of its response to it and legislation is included in the draft Finance Bill published on 10 December 2014. The new regime is […]
As expected, the taxpayer has filed a Supplementary Memorandum of Fact and Law in its transfer pricing appeal in the Federal Court of Appeal.
Earlier, the Federal Court of Appeal allowed the taxpayer’s motion to add a new ground of appeal and to file a supplementary factum.
(See our previous posts on the McKesson transfer pricing appeal here and here.)
The taxpayer’s Supplementary Memorandum of Fact and Law is substantially identical to the draft factum that it […]
Tax legislation expected to be signed into law by President Obama increases certain civil penalties by indexing those penalties to inflation and also raises the threshold by which the IRS must report refund claims to the Joint Committee on Taxation (JCT).
H.R. 5771, which extended previously expired tax provisions to the end of 2014, also raises the threshold for JCT’s mandatory review of C corporation refund claims from $2 million to $5 million under Section […]