Regulatory Analysis

Posted September 29, 2017 by Sovos
IRS FATCA File Status Notification

Due to a VERY high volume of files coming into the IRS, the sending out of File Status Notifications by the IRS will take longer than usual over the next few days.

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Posted September 28, 2017 by Sovos
IRS Notice Addresses Narrowing in Circumstances in Which a Foreign TIN is Required

The IRS released a notice detailing forthcoming changes to Chapter 3 of the Internal Revenue Code ("Code") regarding reporting on Form 1042-S. Specifically, the IRS reported that the amendment will narrow the circumstances in which a Foreign TIN and date of birth ("DOB") will be required.  A phase-in period will be adopted for FIs to […]

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Posted September 28, 2017 by Sovos
IRS Releases Notice Detailing Procedures for FFIs required to report U.S. TINs under FATCA Model 1 IGAs

The IRS released an advance version of Notice 2017-46 which details procedures for FFIs required to report U.S. TINs under FATCA Model 1 IGAs. In this advance notice, the IRS establishes that they will not determine that there is significant non-compliance with reporting obligations under an applicable Model 1 IGA during calendar years 2017, 2018, […]

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Posted September 27, 2017 by Sovos
Latest Senate ACA Repeal Effort Falls Short

The Senate announced that the Graham-Cassidy bill to repeal the Affordable Care Act would not be brought forward to a vote. The bill was announced approximately two weeks ago and seemed to have some momentum. However, Senators McCain (R-AZ) and Paul (R-KY) quickly came out against the bill. On Monday, Senator Collins (R-ME) announced that she […]

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Posted September 26, 2017 by Ramón Frias
Puerto Rico Extends Sales Tax Holiday for Prepared Food

As posted to the Twitter Feed for the Treasury Department of Puerto Rico (Hacienda), the sales tax exemption for prepared food has been extended until October 8. The information released on Twitter does not make any reference to a regulation or ordinance, likely due to limited infrastructure and capabilities currently available in Puerto Rico in […]

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Posted September 25, 2017 by Ramón Frias
Puerto Rico May Have Enacted another Sales Tax Holiday

News from Puerto Rico seems to indicate that as result of the devastation created by Hurricane Maria, the Treasury Department of the island (Hacienda) has issued a four-day sales tax holiday for prepared food. This sales tax holiday is would be starting Thursday September 21, and would end Sunday, September 24 2017. This information has not […]

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Posted September 25, 2017 by Paul Ogawa
IRS Issues Corrections to Income Codes in the 2017 Instructions for Form 1042-S

The IRS recently issued a correction to their 2017 Instructions for Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding. The 1042-S is generally used to report payments from U.S. sources to foreign persons. The IRS corrections relate to income codes on page 21 of the 2017 Instructions for Form 1042-S. Income Code 54 […]

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Posted September 25, 2017 by Brendan Magauran
Italian Ministry of Economy and Finance Provides Update on Split Payment System

On September 14, 2017 the Italian Ministry of Economy and Finance published the updated lists of companies that qualify for the revised split payment system. The updated lists cover changes to two categories of companies that are subject to the split payment system in Italy:  Companies lawfully controlled by the Presidency of the Council of Ministers and […]

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Posted September 25, 2017 by Kevin Diffily
Dutch Government Unveils 2018 Tax Plan

The Dutch government has released its Tax Plan for 2018, which includes three provisions relating to the VAT law. First is the abolition of the special scheme for agriculture. The government's explanatory memo states that this plan is being abolished because the modernization of farming has led agricultural businesses to more closely resemble other businesses, thus obviating […]

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Posted September 20, 2017 by Paul Ogawa
North Carolina Releases Notice of Withholding Tax Changes

The North Carolina Department of Revenue has released an information bulletin detailing important information about withholding tax as it relates to employers, pension payers, and other relevant parties. Of particular importance are changes relating to the filing of Form NC-3, the Annual Withholding Reconciliation form, and a change to the withholding rate for Tax Year […]

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Posted September 20, 2017 by Adam Rivera
IRS Releases Proposed Regulation Allowing Use of Truncated TINs on Form W-2s Furnished to Employees

The IRS has recently released Proposed Regulation REG-105004-16, which would allow the use of truncated Taxpayer Identification Numbers (TINs) on Forms W-2 furnished to employees. The main thrust of this proposal would be to aid employers’ efforts to protect employees from identity theft, and these proposed regulations would amend existing regulations to permit employers to […]

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Posted September 20, 2017 by Jesse Rooney
Missouri Releases Filing Guidelines for Electronic Filing of W-2s, 1099s

Missouri’s Department of Revenue has released electronic guidelines for electronic filings of W-2s and 1099s. This follows a prior announcement that employers filing 250 or more W-2s for tax year 2017 will need to file with the Department electronically by January 31, 2018. The Department will continue to accept W-2s from employers with fewer than […]

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Posted September 20, 2017 by Sovos
UK HMRC Opens Consultation for Further “Making Tax Digital” Legislation

Last week, Her Royal Majesty’s Revenue and Customs (HMRC) announced the opening of a consultation period regarding the current legislation for the “Making Tax Digital” initiative, which is slated to take effect from April 2019. In its announcement, HMRC provided links to summaries regarding the current content of related legislation, and alerted consumers that they have […]

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Posted September 20, 2017 by Sovos
Croatian Ministry of Finance Clarifies VAT Exemption Under Article 39(1)(m) of the Croatian VAT Act

The Croatian Ministry of Finance has issued clarifying guidance related to the VAT exemptions available to non-profit entities under Article 39(1)(m) of the Croatian VAT Act. Section 1(m) of Article 39 states that "services closely related to sport or physical education performed by non-profit legal persons, to persons engaged in sport or participating in physical […]

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Posted September 19, 2017 by Ramón Frias
Puerto Rico Postpones Again Deadline for September Tax Obligations

The Treasury Department of Puerto Rico issued Circular Letter 17-18 announcing another postponement of certain deadlines relating to the payment and filing of taxes – including sales tax. The postponements are intended to give businesses opportunity to recover from the possible effects of Hurricane Maria. By way of a quick summary: The deadline for the […]

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Posted September 19, 2017 by Ramón Frias
Another Possible Sales Tax Suspension in Puerto Rico

On September 18, 2017, the Governor of Puerto Rico declared again a commonwealth-wide state of emergency related Hurricane Maria, which is on track to impact the island. Under existing law, should this “state of emergency” turn into a “disaster declaration” the Puerto Rico Department of Revenue retains the authority to temporarily suspend state and local sales […]

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Posted September 19, 2017 by Sovos
Australia Introduces Legislation to Remove Double Taxation on Digital Currency

The Australian Treasury has recently introduced the Treasury Laws Amendment (2017 Measures No. 6) Bill 2017, which alters the GST treatment of digital currency. In an effort to promote more international commerce business in Australia, the proposed bill removes the GST obligations from digital currency effectively putting such currency on even footing with any other physical currency in circulation. More […]

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Posted September 19, 2017 by Jesse Rooney
Cayman Islands Closes AEOI Portal, Issues Statement on Late Filing

The Cayman Islands’ Department for International Tax Cooperation closed its AEOI portal on September 13. The portal was originally scheduled to be closed on August 31 in line with the Department’s deadline for AEOI reporting, but the Department kept the portal open until September 13 to accommodate late filers. The Department stated that it will […]

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