Top 10 Tax Headlines from All Regions The August applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.6%, the lowest rate so far this year. Brazil has signed tax treaties with the following countries which have not been ratified yet and, therefore, are not currently in force: Paraguay, Russia, Trinidad and Tobago and Venezuela. On July 22, the Tax Court published its decision in the case of Anschutz Company v. Commissioner, involving a taxpayer that (indirectly) engaged in various prepaid variable forward contracts (which the court calls "PVFCs") and associated stock lending agreements ("SLAs") with respect to portfolio stock (indirectly) owned by him. As of the beginning of August, Congress has not passed any of the tax legislation that has been expected. There has been much publicity given to CRA’s announced program to audit Family Trusts with a view to determine whether certain trusts offend income splitting avoidance tax rules. The OECD Global Forum's peer review process is now underway to check the progress of implementation of the International Tax Standard In May, the House of Representatives passed legislation (Section 413 of H.R. 4213) that would subject non-wage earnings of certain S corporation shareholders to the self-employment tax for the first time. The final Advisory from OSFI on accounting and capital matters related to the conversion to International Financial Reporting Standards (IFRS) by Federally Regulated Entities (FREs) was released in March 2010. The general statutory corporate income tax rate for entities incorporated in Argentina including branches or permanent establishments of foreign companies is 35%. On August 10, 2010, the House passed, without change, the Senate’s version of H.R. 1586, sending the bill to President Obama. The President signed the legislation later that day. |