Monthly Archives: March 2012

Easing the pain of FATCA

Urged  by the financial services industry  that the rules under FATCA would be “totally unworkable” the IRS issued several Notices (2010-60, 2011-34 and 2011-53) to ease the implementation of FATCA. Now come the proposed Regulations containing some relief, especially in the start date of the obligations under the Act. The proposed regulations exclude from the definition of withholdable payment any payment made under an obligation outstanding on 1 January 2013. Therefore payments on obligations entered into before 1 January 2013 … Continue reading

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Government moving the Pt IVA goalposts?

The old tax analogy is that you never won the game against the Commissioner of Taxation, you merely won the first half and at halftime the Commissioner moved the goalposts. While online viagra things changed slightly with the ATO’s legislation drafting area moving into Treasury, the Government is currently looking at it’s ultimate “fullback”, ITAA 1936 Pt IVA and has announced its intention to improve Pt IVA’s robustness against the “commercial transaction” play. The standard consultation procedure will be done, … Continue reading

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