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International Tax

Newsletter

 

This e-newsletter gives you an overview of international tax developments being reported globally by KPMG member firms in the Americas Region between 1 March and 31 March 2014.

Brazil Cayman Islands Mexico Venezuela
British Virgin Islands Chile Peru  
Canada Jamaica USA  

For a full summary of global tax developments, visit kpmg.com/TaxNewsFlash.

To contact the International Tax Team email internationaltax@kpmg.com.

  Tax area concerned Relevant date Description of measures and publication link (Considerations in italic where necessary)
Brazil
Tax legislation adopted and regulatory update Social security taxation March 2014 Guidance (Instrução Normativa nº 1.453/2014) has been published in Brazil concerning changes to the rules for social security taxation and for the collection of social security contributions and other funds managed by the tax authority.
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British Virgin Islands
Treaties EOI 11 March 2014 An agreement for the exchange of tax information between the British Virgin Islands and Canada entered into force on 11 March 2014.
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Canada
Tax legislation adopted and regulatory update British Columbia budget 18 February 2014 Bill 8—which implements certain measures in British Columbia's 2014 budget—received Royal Assent on 24 March 2014.
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Individual Income Tax 2014 Canada’s Department of Finance released a Notice of Ways of Means Motion on 24 March 2014 to implement selected measures announced in the 2014 budget.
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Mining activity taxation 2014 Besides taxation at the federal government level, each of Canada’s provinces and territories (except for Prince Edward Island, which has no mining activity) also imposes separate mining taxes on mining activities or royalties from mining.
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Tax compliance 31 July 2014 There is some filing relief for taxpayers owning certain types of foreign property provided by the Canada Revenue Agency.
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Proposed legislation Newfoundland and Labrador budget 2014 Newfoundland and Labrador Finance Minister delivered the province’s 2014 budget.
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Saskatchewan Budget 2014 Saskatchewan Finance Minister on 19 March 2014 delivered the province's 2014 budget.
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Reporting standards for oil and gas industry June 2015 Oil and gas and mining companies operating in Canada may have to act quickly to meet rigorous new financial and tax transparency reporting standards that could be in place as early as next year.
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GST/HST 2015 Canada’s 2014 federal budget proposed a significant makeover to one of the most popular GST/HST relief elections used by many businesses across Canada. Read more
Surtax on imports First half of 2015 Canada may proceed with a 100 percent surtax on selected U.S. imports in the first half of 2015. The tax may affect Canadian businesses that import or export products.
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Alberta budget 2014 Alberta’s Finance Minister on 6 March 2014 delivered the province’s 2014 budget.
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Manitoba budget 2014 Manitoba’s Finance Minister on 6 March 2014 delivered the province’s 2014 budget.
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Taxation of banks February 2014 Canada’ Department of Finance released draft legislation on the taxation of Canadian banks with foreign affiliates in late February 2014.
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Non-profit organizations 2014 A recent report issued by the Canada Revenue Agency indicates that a significant number of incorporated non-profit organizations  in Canada do not comply with the rules in the Income Tax Act that provide for an exemption from tax on their activities.
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Anti-avoidance legislation 2014 Canadian taxpayers—including Canadian-based multinationals—with arm’s length commercial lending arrangements could be unexpectedly affected by the 2014 federal budget’s new thin capitalization and withholding tax proposed anti-avoidance measures targeting certain back-to-back loan arrangements.
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Treaties FTA Mid 2015 Representatives of the governments of Canada and South Korea signed a free trade agreement in March 2014.
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KPMG publications Taxation of REITs December 2013 The increasing popularity of real estate investment trusts (REITs) and similar vehicles demonstrates the growing demand for tax efficient, liquid and transparent vehicles for investing in real estate.
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Cayman Islands
Tax legislation adopted and regulatory update FATCA March 2014 A release from the Ministry of Financial Services, Commerce and Environment of the Cayman Islands states that: (1) the U.S. concept of “responsible office” with respect to FATCA will not be transposed into Cayman procedures; and (2) a Cayman implementing framework for FATCA will enact specific compliance obligations and responsibilities.
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Chile
Tax legislation adopted and regulatory update Foreign tax credit rules 31 January 2014 Changes to the income tax law in Chile affect the credit claimed for income taxes paid or withheld abroad.
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Treaties FATCA March 2014 The Treasury Department posted text of an intergovernmental agreement (IGA) signed by representatives of the governments of Chile and the United States to implement the U.S. legislation known as FATCA.
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KPMG publications Taxation of mining operations 2014 KPMG’s Global Mining Institute recently released its mining guide for Chile. The mining guide covers the competitive landscape of the mining industry in Chile, with respect to the economic, fiscal, and regulatory environment.
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Jamaica
Tax legislation adopted and regulatory update Loss limitation rules 1 January 2014 In Jamaica, the rules limiting the carryforward of losses allow taxpayers to carry forward only those losses that are equal to 50 percent of chargeable income.
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Mexico
Tax legislation adopted and regulatory update Tax certainty agreement 30 November 2018 The 2014 tax reform provisions brought significant changes to the tax system in Mexico—changes affecting both business and individual taxpayers. In response, taxpayers filed for injunctive relief against certain measures under the recently enacted tax provisions.
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Administrative and case law Tax procedure for freezing bank accounts Tesis Aislada CXXIV/2014 (10a) The first chamber of Mexico’s Supreme Court held that a procedure, under Mexico’s tax law, of not notifying a taxpayer before the tax authorities place a hold (or freeze) on the taxpayer’s bank deposits does not violate the constitutionally guarantee for due process and a preliminary hearing.
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Peru
Tax legislation adopted and regulatory update VAT 15 March 2014 Peru’s tax administration issued guidance concerning:
Implementation of electronic access to the customs drawback return system
When the tax administration may allocate amounts to “drawdown accounts”
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USA
Tax legislation adopted and regulatory update Transfer pricing 2013 The IRS released an advance copy of Announcement 2014-14 providing the statistics of the APA program for 2013.
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- - For legislative changes and regulatory updates for the US please visit below link to the TaxNewsFlash United States.
Read TaxNewsFlash US

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Venezuela
Tax legislation adopted and regulatory update Currency exchange platform March 2014 In Venezuela, a new foreign currency exchange “Decree-Law” allows for the creation of a new additional platform, giving private companies access to foreign currency (e.g., US dollars) at market rates.
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