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Proposed letter to SARS on commencement of an audit

We refer to your letter dated ………………………………… which requests information and documentation in terms of s74A of the Income Tax Act, No. 58 of 1962 (“the Act”) and s57A of the Value Added Tax Act, 89 of 1991 (“the VAT Act”) [OR ss 40 to 49 of the Tax Administration Act, 2011 (“the TAA”)] and […]

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USA The Flexible Foreign LLC

The Ever Flexible Foreign LLC originally POSTED BY JIMMY SEXTON | MAY 11TH, 2013 at  http://nomoretaxtrouble.com/blog/flexible-foreign-llc/ People form foreign Limited Liability Companies (LLC) for a variety reasons. They do this because foreign LLCs are very flexible entities and can be used for anything from holding a portfolio to running a business. Foreign LLCs generally offer superior […]

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Tax Risk Management Survey results

Africa is certainly ‘hotting up’ on tax audits and disputes. Here are the interim tax survey results: 1. Do you have an in-house tax team? YES – 45% NO – 55% 2. What degree is your business tax compliant 100% – 33% Don’t know – 10% 3. Do you have a documented tax strategy? YES […]

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South Africa – Statistic extracts from the SARS Annual report

South Africa – Statistic extracts from the SARS Annual report Below are extracts from the most recent SARS Annual Report. Highlights: 843 972 taxpayers have been penalised with a total penalty amount of R3.9 billion 52.5% of taxpayers received administrative penalties and 96% of these taxpayers have paid R862 million for penalties due 26 612 audit […]

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Weekly Tax News from around the Globe by IBFD

THE MORE DETAILED EXPLANATIONS APPEAR BENEATH THIS LIST Australia Treasury consults on modern global economy Bahrain; Estonia Treaty between Bahrain and Estonia ratified by Bahrain Brazil Tax deduction for donations and sponsorships to PRONON and PRONAS – Regulations issued Czech Republic; Kazakhstan Protocol to treaty between Czech Republic and Kazakhstan – second round of negotiations […]

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IRS Data (Fiscal years 2011/12) statistics that affect your tax practice

IRS Data (Fiscal years 2011/12) statistics that affect your tax practice: No. of returns filed: 237,345,000 The estimated number of returns filed by the EAs and CPAs receiving this notice is estimated at a rounded up figure of 100,000 returns per year. Therefore, I am applying the IRS national statistics to this segment to give you […]

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Section 232 of the South African Constitution states: Customary international law is law in the Republic unless it is inconsistent with the Constitution or an Act of Parliament.

Introduction to International Tax Law by Prof D N Erasmus with an extract of notes from TJSL Section 232 of the South African Constitution states: Customary international law is law in the Republic unless it is inconsistent with the Constitution or an Act of Parliament. 1.2 What is International Tax Law and 1.3 Introduction to Organizations […]

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JUDGMENT: SARS not a preferred creditor in business rescue proceedings

In the attached judgment, the Western Cape High Court held that SARS was not a preferred creditor in business rescue proceedings. Please select to download: SARS v M.B. Beginsel N.O & Another

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Transfer Pricing in the Gas & Oil Sector: Kuala Lumpur 6 & 7 December 2012

Workshop Overview: The 2-day workshop will be highly interactive with hands-on case studies to create practical examples of the transfer pricing challenges facing multi-national corporations and designed to enhance the team’s ability to identify, prioritize, assign solutions and contribute to improved tax risk reduction strategies on transfer pricing. In the workshop, delegates will play the […]

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