Canada: Relieving Amendments To Trust Loss Restriction Rules For Investment Funds

On October 20, 2014, the government tabled in the House of Commons a Notice of Ways and Means Motion containing proposed amendments to the Income Tax Act (Canada) (“Tax Act”) providing relief from the loss restriction event rules for certain investment funds that are mutual fund trusts under the Tax Act, or that would be mutual fund trusts if they had 150 unitholders.

Generally, the loss restriction event rules result in a deemed taxation year-end […]

By |October 23rd, 2014|

Non UK Resident Individuals Owning UK Residential Property – New Capital Gains Tax Charges From 6 April 2015

New capital gains tax charges from 6 April 2015

The Government announced plans in the March 2014 Budget to introduce capital gains tax (CGT) on the sale of UK residential property by non-UK residents with effect from 6 April 2015. More details of how this legislation will apply should be available later this year, possibly when the draft Finance Bill clauses are published on 10 December 2014.

At this stage there are a lot of areas […]

By |October 22nd, 2014|

South Africa: Reportable Arrangements – Proposed Replacement Of The Existing Notices For Purposes Of Sections 35(2) And 36(4) Of The Tax Administration Act No. 28 Of 2011

Section 35(2) of the Tax Administration Act No. 28 of 2011 (the “TAA”) currently provides that an arrangement will be reportable, inter alia,if it is listed as such by the Commissioner for the South African Revenue Service (“Commissioner” or “SARS”) by public notice, and if the Commissioner is satisfied that the arrangement may lead to an undue tax benefit. Such inclusions are, however, subject to the provisions of section 36 of the TAA, which […]

By |October 22nd, 2014|