United States: Treasury Announces Relief For Countries With In-Substance FATCA Igas

On December 1, 2014, the U.S. Treasury Department announced that countries that have reached FATCA inter-governmental agreements (IGAs) in substance but have not signed the agreements by the December 31 deadline will, under some conditions, still be treated as having intergovernmental agreements in effect. Treasury said that to be treated this way, the jurisdictions must demonstrate “firm resolve” to sign the IGAs as soon as possible. After December 31, Treasury will review the list […]

By |December 10th, 2014|

Nigeria: Court Of Appeal Upturns The Decision Of Federal High Court On The Deductibility Of Expenses By Non Resident Companies Under The Deemed Profit Basis

We understand that the Court of Appeal has reversed the long standing decision of the Federal High Court (FHC) regarding the treatment of sub-contracting expenses in the determination of deemed profit of a non resident company.

The FHC had ruled in a case between the FIRS and Haliburton to the effect that payments by the foreign entity to a Nigerian subcontractor should not be included in the turnover of the foreign entity used in calculating […]

By |December 10th, 2014|

Canada: Reminder: CRA Deadline For Eliminating HST/GST Joint Venture Reporting By Nominees

As a follow-up to our communication dated February 7, 2014, this is a reminder of the December 2014 deadline imposed by Canada Revenue Agency for disallowing joint venture arrangements in which nominee corporations may file HST/GST returns and remit HST/GST for the joint venture.

Background

A joint venture election made for HST or GST purposes permits most purchases and sales made for the account of a qualifying joint venture (such as co-ownership of rental real estate […]

By |December 9th, 2014|