United States: Sixth Circuit Holds SUB Payments Not Subject To FICA Taxes Employers Should Consider Filing Refund Claims

In a recent decision, the Sixth Circuit Court of Appeals held that severance payments to former employees that are supplemental unemployment compensation benefits (SUBs) are not “wages” for FICA tax purposes. United States v. Quality Stores, Inc., No. 10-1563, 2012 U.S. App. LEXIS 18820 (6th Cir. Sept. 7, 2012).This decision is at odds with the Federal Circuit decision in CSX Corp. v. United States, 518 F.3d 1328 (Fed. Cir. 2008). (For our prior analysis of the […]

By |November 10th, 2012|

Nigeria: Newsflash On The Companies Income Tax (Exemption Of Profits) Order, 2012

Introduction
The President of the Federal Republic of Nigeria recently issued an order which confers certain fiscal incentives on companies doing business in Nigeria. The incentives are in the form of tax exemptions/reliefs – not tax credits – and are aimed at encouraging employment, employee-retention and infrastructural development in the country.

The Companies Income Tax (Exemption of Profits) Order, 2012 (the Order) was made by the President in exercise of the powers under section 23(2) of […]

By |November 8th, 2012|

India: Tax Relief to Software Industry

New Notification
The Indian Government has issued a notification on 13 June 2012 (“Notification”), pursuant to which tax will no longer be deducted on multi-level software payments made to a resident, subject to certain conditions discussed below. The new provision will come into force from 1 July 2012.
Background & Budget 2012
The Indian tax laws, until recently, were capable of varying interpretations on characterization of income from software payments in view of the conflicting decisions of […]

By |November 4th, 2012|