The biggest news in the U.S. capital markets in the second
quarter 2010 was the conference agreement on the Dodd-Frank Wall
Street Reform and Consumer Protection Act (the "Dodd- Frank
Act"). The Dodd-Frank Act passed the U.S. House of
Representatives on June 30, 2010, and passed the Senate on July 15,
2010. While tax had little to do with the Dodd-Frank Act, the
Dodd-Frank Act will have an impact on "trust preferred"
offerings. The Dodd-Frank Act may also be remembered for what it
didn't do with regard to the taxation of derivatives and
covered bonds.
In other news, the Internal Revenue Service (the
"IRS") released taxpayer friendly proposed regulations
clarifying ambiguities in the debt modification regulations,
providing that deterioration in the financial condition of an
issuer will generally be ignored in determining whether a modified
debt is not debt for U.S. federal income tax purposes....
Specific Questions relating to this article should be addressed directly to the author.
Recent statements by Prime Minister Kevin Rudd’s government to impose a super tax of 40% on profits of mining projects in Australia from July 2012, have created much consternation among mining executives and investors in Australian mining companies.
The Full Federal Court of Australia has upheld the Federal Court’s decision that the "Hummer", and potentially other vehicles not fitting within the traditional description of "luxury car", will now be subject to the luxury car tax ("LCT") on top of GST and other customs and excise duties wherever applicable.
In a sleight-of-hand move dexterously played by the Canada Revenue Agency ("CRA"), it managed to secure advance collection of a disputed corporate income tax debt by obtaining an ex parte jeopardy collection order after the CRA was notified of an application by the taxpayer to appoint a receiver.
If the annuity contract holder is a natural person, income on the annuity contract will generally not be taxable during the accumulation period of a deferred annuity.
Successful advisors of high net worth individuals employ a holistic approach to their clients’ planning, one that addresses all of the clients’ goals simultaneously, rather than focusing on component goals in isolation.
The Canadian Federal Court of Appeal recently overturned the Tax Court of Canada’s 2008 decision regarding the international transfer pricing of cross-border supplies of pharmaceutical ingredients in the case of GlaxoSmithKline Inc. v. Canada.
On July 22, the Tax Court published its decision in the case of Anschutz Company v. Commissioner, involving a taxpayer that (indirectly) engaged in various prepaid variable forward contracts (which the court calls "PVFCs") and associated stock lending agreements ("SLAs") with respect to portfolio stock (indirectly) owned by him.
