TaxNewsFlash-Americas 2001 Editions

December 2001

Issue

Date

Subject

2001-Alert

December 19, 2001

Canada: Draft Rules for Non-Resident Trusts and Foreign Investment Entities: Effective Date Is Delayed

2001-25

December 13, 2001

Canada: Departure Tax — CCRA Moving on Election Form
Canada: Finance Canada Tables Federal Budget
Canada: Non-Residents Get Rental Income Late-Filing Amnesty until December 31
United States-Antigua and Barbuda: United States, Antigua and Barbuda Sign Exchange of Information Agreement
Netherlands Antilles: Dutch Lower House of Parliament Approves New Tax Arrangement with Netherlands Antilles and Aruba
Costa Rica: Update: Free Trade Zone Declaration Rules, Tax Audit Criteria for Custom Operations, New Form for Reporting Withholdings, and Changes in Tax Domicile Reporting Requirements
Venezuela: Changes in the Taxation of Hydrocarbon Exploitation and Land Suitable for Agricultural Use
Andean Region: U.S. Senate Bill Would Grant Preferential Treatment for Certain Products from Andean Countries
Argentina: Tax Changes Proposed in Pending Legislation

November 2001

Issue	Date	Subject
2001-24	November 29, 2001	Canada: Taxation Committee Urges Delay on Non-resident Trust and Foreign Investment Entity Rules Canada: Ontario Corporate Tax Cuts “Substantively Enacted” Canada: Federal Budget to Be Tabled on December 10, 2001 Cayman Islands: Agreement to Exchange Tax Information With the United States Is Signed Guatemala: Changes to Tax Laws Concerning Charitable Donations and Loss Carryforwards Costa Rica: Tax Incentives for Filing Returns and Paying Taxes Through the Internet Colombia: Tax Consequences on the Sale of Commercial Establishments and Lines of Business Brazil: Brazilian Companies May Defer 2001 Exchange Losses for Financial Statement Purposes
2001-23	November 15, 2001	Canada: Finance Canada Announces Budget for December 2001 Canada: Importer's Certificate of Origin No Guarantee of Preferential Duty Status Canada: 2002 Quebec Budget Is Presented Canada: Withholding Tax Relief for Foreign Bank Branches Mexico: Video Conference on Mexico's Tax Reform Scheduled for November 29 Costa Rica New Rules for Determining Tax Domicile; New Interest Rate for Taxes Due Venezuela: Procedural Changes Included in Recent Reform of the Organic Tax Code Argentina: Recent Court Case Renews Hope for Obtaining Favorable Withholding Tax Rate for Software Royalties Argentina: Government Issues Tax-Related Decrees to Boost Argentina's Economy and Bond Market Chile: New Tax Treaty Signed with Norway
2001-22	November 1, 2001	Canada: Securities Donated to Charities - Capital Gains Tax Break Made Permanent Canada: Taxable Canadian Property Disposition — New Document Requirements Canada: CCRA Reviews Interest Deductibility Canada: CCRA Announces New Policy on the Tax Treatment of Employee Gifts and Awards Mexico: Supreme Court of Justice Affirms Ruling That 40% Withholding Rate for Low Tax Jurisdictions Is Unconstitutional Costa Rica: New Tax Law Includes Changes Affecting Business Taxpayers Chile-United States: Social Security Agreement Between Chile and the United States Enters Into Force December 1, 2001

October 2001

Issue

Date

Subject

2001-21

October 18, 2001

Canada: 2001 Canadian Tax Foundation Conference -- Updates from CCRA and Finance Canada
Canada: Ontario Speeds Up Corporate Tax Cuts
Mexico: Amnesty to Settle Liabilities Relating to Creditable Subsidy Paid to Employees
Costa Rica: New Income Tax Rates Announced for 2002
Colombia: Update on Customs Service Charge
Argentina: Update: Using Argentine Bonds to Satisfy Tax Debts
OECD: Committee on Fiscal Affairs Publishes Draft Contents of the 2002 Model Tax Convention Update

2001-20

October 4, 2001

Canada: Supreme Court Rules on Interest Deductibility
Canada: Matchable Expenditure Changes Wrap Up Film Tax Shelters
Canada: Fall 2001 Round-up of Sales and Local Tax Issues
United States: Legislation Introduced to Encourage Economic Activity in Puerto Rico and U.S. Possessions
Costa Rica: Certain Asset Acquisitions May Be Deductible; Taxes Can Be Filed and Paid Via the Internet; New Registry Requirements for Importers
Argentina: Tax Treaty with Norway Is Approved
Argentina: Reintroduction of Export “Drawbacks”

September 2001

Issue

Date

Subject

2001-19

September 20, 2001

OECD: Financial Action Task Force Reports on Developments in "Non-Cooperative" Jurisdictions
Canada: CCRA Suspends Alternative Methods of Reporting to Customs
Netherlands Antilles: Final Negotiations for Tax Arrangement for the Kingdom of the Netherlands
Venezuela: Organic Tax Code Includes Controversial Criminal and Civil Provisions

2001-18

September 6, 2001

Canada: Transfer Pricing Crackdown - Watch Out for New 20% Penalty
Canada: Accounting for Recent Federal and Provincial Tax Cuts
Canada: Ontario Property Tax Rebates for Vacant Buildings; 2001 Rebate Applications Due by February 28, 2002
Colombia: VAT Implications for Electronically Delivered Software
Venezuela: Tax Administration Considers Changes to Income Tax and Business Asset Tax Laws
Netherlands Antilles: Legislation Rationalizes Tax Administrative Procedures
Argentina: Regulations Offer Guidance for Taxpayers Using Argentine Bonds to Pay Tax Debts
Argentina: Government Reaffirms Policy to Treat Short Period as a Full Year for Loss Carryforward Purposes

August 2001

Issue

Date

Subject

2001-17

August 23, 2001

Canada: Non-Resident Trusts and Foreign Investment Entities - Revised Draft Legislation Released
Canada: British Columbia Cuts Provincial Corporate Tax Rates
United States: Analysis: Recent IRS Notice Retroactively Reduces Burden of Foreign Corporations to Report Treaty-Based Return Positions
Colombia: Pending VAT Credits and Deductions Must Be Claimed in 2001, or May Be Forfeited
Brazil: Legislature to Consider Arm's-Length Principle for Transfer Pricing Rules
Argentina: Taxpayers May Use Argentine Bonds to Pay Certain Tax Debts

2001-16

August 09, 2001

Summary and Updates Page

OECD: Narrows Focus of "Harmful Tax Competition" Project
Canada and Peru Sign Tax Treaty
Canada: Corporate Aircraft on CCRA's Radar Screen
Mexico: Clarification on Calculating the Withholding Tax on Dividends
Guatemala: Guatemalan Legislature Approves New Tax Increases
Argentina: Plan to Eliminate Budget Deficit Includes Tax Provisions

July 2001

Issue

Date

Subject

2001-15

July 26, 2001

Summary and Updates Page

Canada-Venezuela: New Tax Treaty Establishes Withholding Rates
United States: Update of Tax Treaties
Costa Rica: High Court Declares Assets Tax Unconstitutional, Retroactively
Costa Rica: Commerce Minister Proposes Corporate Tax Rate Reductions, to Comply With WTO Agreement
Colombia: Update on New Customs Service Charge
Venezuela: Text of Venezuela-Denmark Tax Treaty
Ecuador-Canada: Tax Treaty Is Signed
Brazil: President Proposes "Mini-Tax Reform" Package That Includes Constitutional Changes
Chile: New Measures Affect Thin Capitalization Rules

2001-14

July 12, 2001

Summary and Updates Page

Canada: New Deadline for Emigrants to Post Security for Departure Tax
Canada: Ontario Corporate Tax Cuts Become Law
Costa Rica: Certain Taxpayers May Be Subject to Audit for Revalued Assets
Colombia: Guidance Related to Expiring NOL Carryforwards
Venezuela: Venezuela Agrees to Tax Treaty with Denmark
Brazil: Increases in PIS and COFINS Rates for Medicine, Pharmaceuticals, and Cosmetics
Argentina: Measures Providing Tax Relief and Reform Are Proposed

June 2001

Issue	Date	Subject
2001-13	June 28, 2001	Summary and Updates Page European Union: KPMG Releases European Tax Handbook Canada Signs New Tax Treaties with Czech and Slovak Republics Canada: CCRA's Prescribed Interest Rates Going Down Canada: International Drug Studies Eligible for R&D Tax Credits United States: Subpart F Contract Manufacturing Implications of MedChem Guatemala: Greater Flexibility Allowed for Use of Foreign Currency Costa Rica: Special Tax to Be Imposed on Offshore Banks and Financial Entities Argentina Pegs Currency to Both U.S. Dollar and Euro
2001-Alert	June 15, 2001	Canada: Tax Law Receives Royal Assent; Includes Rate Reductions for Corporations and Individuals
2001-12	June 14, 2001	Summary and Updates Page United States: Summary of Tax Legislation Brazil: OECD Economic Survey Discusses Tax Policy Argentina: Capital Gains Taxed to Argentine Individuals and Foreign Holding Companies Argentina: Value Added Tax Modifications

May 2001

Issue	Date	Subject
2001-11	May 31, 2001	Summary and Updates Page OECD: United States Joins Other Countries in Criticizing OECD "Harmful Tax Competition" Project Canada: Finance Canada's Economic Statement Replaces Spring Budget Canada: Transfer Pricing Issues for International Loans and Guarantees - Beware "Rules of Thumb" Colombia: Employment, Export Tax Credits Continue to Offer Benefits Colombia: Taxpayers Continue to Enjoy Specific Exemptions in Free Trade Zones Argentina Approves Tax Relief for Automobile Sales Other Developments: United States (see Summary and Updates page)
2001-10	May 17, 2001	Summary and Updates Page Canada: Ontario's 2001 Budget Sets Timetable for Corporate Tax Cuts Canada: Ontario EHT Still Payable on Exercise of Non-Research-Intensive Stock Options Canada: Spring 2001 Round-Up of Sales & Local Tax Issues Mexico: Congress Approves Financial Incentives; Expenditures to Be Cut Due to Lower-Than-Projected Revenues Argentina: Tax Treaty with Switzerland Provisionally Enters Into Force Chile: Legislation Takes Aim at Tax Evasion Other Developments: United States, Argentina (see Summary and Updates page)
2001-09	May 3, 2001	Summary and Updates Page International: KPMG Corporate Tax Rate Survey Finds Inter-Regional Convergence European Union: Tax and Accounting Implications of Euro Conversion Canada: Building an Effective e-Tax Plan into an e-Business Strategy Canada Signs New Tax Treaty with Germany Canada: Deadline Extended for Deferring 2000 Employee Stock Option Benefits Mexico: Financial Sector Initiatives Included in Tax Reform Proposals Venezuela: Tax Haven Countries Are Identified Brazil: Federal Court Rules That Tax Treaty Prevails Over Domestic Transfer Pricing Provisions

April 2001

Issue

Date

Subject

2001-08

April 19, 2001

Summary and Updates Page

Canada: Provincial Budget Season in Full Swing
United States: OECD Harmful Tax Competition Initiative Criticized
Mexico: Administration's Proposals for Tax Reform
United States, Colombia Agree to Share Tax Information
Other Developments: Venezuela, Brazil (see Summary and Updates page)

2001-07

April 5, 2001

Summary and Updates Page

Canada: Detailed Guidance on APAs Now Available
Canada Enters Tax Treaty Talks with Peru
Guatemala: Increase in Corporate Tax Rate, Liberalization of Banking Laws
Venezuela: Statutory Profit Margins Established for Transfer Pricing Methods
Argentina: New Economic Minister Addresses Bank Transactions, Imports, and Manufacturing Incentives
Other Developments: United States, Mexico (see Summary and Updates page)

March 2001

Issue

Date

Subject

2001-06

March 22, 2001

Summary and Updates Page

Canada: Stock Options: Deadline Extended for 2000 Deferral Elections
Canada: Supreme Court Rules on Partnerships: View to Profit Required
Canada: "Fractions of Employees" in Joint Venture Do Not Add Up to Active Business
Mexico: Related Party Transactions: Maquiladora Transfer Pricing Rules Are Modified
Venezuela: Current Treaty Negotiations
Brazil: Changes to Tax Rates for Royalties Paid to Non-Residents, Certain Banking Transactions
Netherlands Antilles: Economic Zones Are Intended to Encourage Business Activity and E-Commerce
Other Developments: United States (see Summary and Updates page)

2001-05

March 8, 2001

Summary and Updates Page

Canada: Changes Coming for "Foreign Affiliate Property Income" Rules?
Canada: More Flexibility for Certain Tax-Free Rollovers in Québec
Finance Canada "Re-Tables" 2000 Budget's Goods and Services Tax Measures
United States: Update-FSC Repeal and Extraterritorial Income Exclusion Act
United States: IRS Postpones Hearing on Proposed Rules for Sourcing Income from International Communications, Ocean and Space Activities
United States: Proposed Section 894(c) Regulations Would Deny U.S. Treaty Benefits for Certain Payments by Domestic Reverse Hybrids
Mexico: Continuing Discussion and Analysis of Tax Reform Provisions
Argentina: Changes to Tax Treaty Protocol, Automobile Excise Taxes

February 2001

Issue

Date

Subject

2001-04

February 22, 2001

Summary and Updates Page

Canada: General Anti-Avoidance Rule: All Provinces Now Covered
Two New Canadian Tax Letters Available
Mexico: Analysis of Recent Tax Reforms
Colombia: Determining the Value Added Tax Base for Real Estate Construction Services
Chile: Effect of Recent and Pending Legislation on Business Taxation
Other Developments: United States (see Summary and Updates page)

2001-03

February 8, 2001

Summary and Updates Page

Update: OECD Advances on Several Tax-Related Fronts
Canada: Update: Accounting for Corporate Tax Rate Cuts
Canadian Courts: Partnerships Cannot Import U.S. Losses
New Canadian Tax Letter - Making the Most of Tax Incentives for Charitable Donations
United States: IRS Announces Nonresident Alien Voluntary Compliance Program
Peru: Important Tax Law Changes Go into Effect for 2001
Latin America: Income Tax Opportunities Using Tax Treaties

January 2001

Issue

Date

Subject

2001-02

January 25, 2001

Summary and Updates Page

Canada Consults on Free Trade with El Salvador, Guatemala, Honduras and Nicaragua
Finance Canada Issues Draft Rules on Thin Cap Changes and Non-Resident-Owned Investment Corporation (NRO) Repeal
Canada: Act Now to Defer 2000 Taxable Benefits on Publicly-Listed Shares Acquired under Employee Stock Option Plans
United States: Proposed Regulations for Foreign Taxpayers and Foreign Income Included in Treasury's Pre-Inauguration Push
Mexico: New Administration Brings Expectation of Tax Changes
Brazil: Withholding Rate on Technology Payments Remains 15%, but 10% Technology Contribution Payment Imposed
Brazil: Update on Recent Tax Developments

2001-01

January 11, 2001

Summary and Updates Page

Finance Canada Issues 2000 Budget/Mini-Budget Package
Canada: Housekeeping Measures Aired for 2001
Canada: Accounting for Corporate Tax Rate Cuts
Mexico: Tax Reforms Effective Beginning January 2001
Colombia: President Signs Tax Reform Bill Into Law
Argentina: House of Representatives Approves Changes to Tax Treatment of Interest Income

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