A Law To Compel Private Companies Operating In Nigeria To Become Public Companies Is Underway

The Private Companies Conversion and Listing Bill is undergoing legislative proceedings at the National Assembly. The Bill seeks to compel private companies to convert to public companies by becoming listed on the Nigerian Stock Exchange. The treshhold for mandatory conversion is shareholders fund of NGN 40 billion (around USD 250 million), turnover or total assets of NGN 80 billion (USD 500 million). Tax waivers of up to one-third of applicable tax rate may be granted while a fine of […]

By |October 7th, 2014|

United States: Philadelphia School Income Tax Imposed On Undistributed S Corporation Income

Action Item: The City of Philadelphia is imposing its School Income Tax on City residents’ Subchapter S Corporation income, whether or not distributed. This is a departure from prior enforcement of this tax. City residents who are shareholders in Subchapter S corporations should consider filing appeals from the City’s assessment of this tax.

The City of Philadelphia Revenue Department (“City”) is assessing the School Income Tax (“SIT”) on the entire share of a resident S […]

By |October 6th, 2014|

United States: Indiana Supreme Court Holds Foreign Source Dividends Not Deductible In Calculating Net Operating Loss

The Indiana Supreme Court has held that foreign source dividends (FSDs) deductible from adjusted gross income (AGI) are not deductible when calculating a taxpayer’s Indiana net operating loss (NOL) deduction.1 Also, the Court rejected the taxpayer’s argument that the Indiana tax statutes facially violated the Foreign Commerce Clause of the U.S. Constitution by disallowing the FSD deduction in the Indiana NOL calculation, but incorporating the federal domestic source dividend deduction in the same calculation.
Background
Caterpillar, […]

By |October 6th, 2014|