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S.Africa: Constitutional law – Invalidity of legislation for failure to facilitate adequate public involvement in the legislative process

Constitutional law Invalidity of legislation for failure to facilitate adequate public involvement in the legislative process: The Restitution of Land Rights Act 22 of 1994, which deals with restitution of land rights or compensation for individuals and communities deprived of rights in land as a result of racially discriminatory laws or practices, set the cut-off […]

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India and Korea: New memorandum suspends tax collection during MAP

India and Korea: New memorandum suspends tax collection during MAP India and South Korea have signed a new MoU [memorandum of understanding] tax treaty on December 9 to strengthen the ease of doing business in each country. Other countries should follow this example. It is the writer’s view that collection of tax is suspended anyway […]

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TP Minds – Americas – Feb 22-25, 2016 Miami

TP Minds – Americas – Feb 22-25, 2016 Miami I am a confirmed speaker and SILVER sponsor at TP Minds Americas 2016, taking place at the Eden Roc Miami on February 22-25 2016. I would like to advise you about the discounts I can offer on registration to the event. First there is an early […]

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S.Africa: Why the new MAP explanations of SARS are wrong!

What follows is the SARS version. The correct explanation appears below:   MUTUAL AGREEMENT PROCEDURE (MAP) What is a MAP? MAP is a procedure which allows the Competent Authorities or designated representatives of the Competent Authorities from the governments of the Contracting States/Parties to interact with the intent to resolve international tax disputes. MAP is provided […]

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Online TAX SUMMIT

CLICK THIS LINK TO ACCESS OUR BROADCAST CHANNEL TODAY>>> https://www.taxconnections.com/broadcast  Tuesday, 22 September 2015 (GMT 15:00)  (08:00AM PDT-Los Angeles) (10:00AM CDT-Chicago) (11:00AM EDT-New York) (16:00PM BST-London) (17:00PM CEST–Paris) (18:00PM IDT-Tel Aviv) (23:00PM HKT–Hong Kong) (00:00AM JST–Tokyo) and Tuesday, 22 September (01:00AM AEST–Sydney) STARTING 8:00AM PDT (California Time): Corporate Multinational Tax Departments Today- The Tax Provision […]

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Transfer Pricing: In effect hits Coca Cola

NEW YORK — Coca-Cola was notified by the IRS that it owes $3.3 billion more in federal taxes, as well as interest, for 2007 to 2009, the company said Friday. The Atlanta-based company said in a regulatory filing that it believes the assessments from the Internal Revenue Service are without merit and plans to pursue […]

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Treaty between Mauritius and South Africa enters into force

Treaty between Mauritius and South Africa enters into force On 28 May 2015, the Mauritius – South Africa Income Tax Treaty (2013) entered into force. The treaty generally applies from 1 January 2016. From this date, the new treaty generally replaces the Mauritius – South Africa Income Tax Treaty (1996). For details of the new […]

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Cook Islands: FATCA’s impact – this paper applies to many other offshore centres

April/May 2015[1]   Impact of FATCA on Cook Islands Entities[2] TABLE OF CONTENTS Background The key differences between FATCA and IGA Models 1 and 2 What does FATCA Mean for Cook Island Entities When Will a CI Entity be Classified as a Foreign Financial Institution Hedge Funds and Private Equity Funds CI Managers and Advisors […]

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USA Supreme Court: Principles applicable in Africa

21 April 2015 US Supreme Court finding. Rodriguez v. United States, No. 13-9972. Police violated the Fourth Amendment when they extended a traffic stop in order to conduct a dog sniff when there was no reasonable suspicion that justified holding the motorist any longer after the officers checked his license and issued a warning ticket […]

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