Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how IRS audits are initiated and conducted to verify tax return accuracy. It highlights taxpayer duties, righ...
Income Tax : The Court held that indirect share transfers deriving value from Indian assets are taxable. Treaty benefits were denied due to tax...
Income Tax : The content outlines key filing deadlines and highlights penalties for non-compliance. The takeaway is that timely filing and paym...
Income Tax : Overview of US tax credits including refundable, nonrefundable, and partially refundable credits, with examples, forms used, and c...
Income Tax : CBDT issues clarification on Circular 01/2025, stating it applies only to the Principal Purpose Test in certain DTAAs and does not...
Corporate Law : Learn about CRS and FATCA, how India receives foreign account info, and the disclosure requirements for foreign assets and income ...
Income Tax : From April 2025, foreign taxes withheld must be included in total income for accurate reporting under section 198. Aims to prevent...
Income Tax : Explore challenges in TRC applications under DTAA by Indian companies. KSCAA proposes reforms for a simpler, efficient process. Le...
Income Tax : Appendix-I Declaration of no PE in India Declaration required u/s 9 of Income Tax Act, and for claiming relief under an agreement ...
Income Tax : The Tribunal ruled that a Dependent Agent PE arises only if agents habitually conclude contracts or secure orders on behalf of the...
Income Tax : The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty....
Income Tax : The Bombay High Court quashed the AAR’s ruling that denied Mauritius DTAA benefits to Bid Services Division (Mauritius) Limited....
Income Tax : Tribunal held that cost-to-cost reimbursements for IT support services do not qualify as Fees for Included Services (FIS) under Ar...
Income Tax : ITAT Delhi ruled that a valid Tax Residency Certificate (TRC) issued by Mauritius is sufficient proof of residency to claim benefi...
Income Tax : The Finance Ministry notifies the India-Belgium protocol amending the 1993 tax treaty, effective June 26, 2025, updating definitio...
Income Tax : Notification implements the India-Qatar Double Taxation Avoidance Agreement (DTAA) and Protocol, effective from the next fiscal ye...
Income Tax : Explore the Notification No. 33/2024 on the agreement between India and Spain for tax exchange. Understand its implications and ch...
Income Tax : Explore implications of Notification No. 21/2024 from Indias Ministry of Finance regarding the tax information exchange pact with ...
Income Tax : Notification No. 96/2023-Income Tax: Learn about the agreement between India and Saint Vincent for tax information exchange and as...
IRS rules strictly require S Corporations to maintain a single class of stock and comply with passive income thresholds. Violations can trigger termination of S status and reclassification as a C Corporation.
Explains new UAE corporate tax guidance on family foundations, transparency rules, investment activity limits and compliance duties.
IRS Publication 523 allows taxpayers to exclude up to 500,000 of gain if ownership and residence tests are met. The article explains eligibility, exceptions, and reporting requirements under U.S. tax law.
Explains why U.S. citizens and resident aliens must report global income and how exclusions apply. The key takeaway is that living abroad does not remove U.S. filing obligations.
Indian residents using a US LLC must treat global LLC profits as taxable in India, even if funds remain in a US bank, with careful attention to entity classification and foreign tax credit.
Explains how the IRS defines self-employment, including sole proprietors, contractors, partners, and gig workers, and clarifies who must comply with SE tax rules.
Explore how GST reverse charge, multi-state registration, and cross-border royalties create compliance hurdles for related-party transactions, emphasizing proper documentation and reporting.
The Karnataka High Court ruled that interconnect service charges paid to non-resident telecom operators do not constitute royalty. The appeal by DCIT was dismissed, following a prior Co-ordinate Bench decision.
Highlights how the Court ruled that consistent operational control and strategic oversight in India can establish a Fixed Place PE under the DTAA, even without exclusive offices. Key takeaway: substance and economic activity override formal ownership.
Supreme Court rules that foreign taxpayers without current projects or PE in India can still set off expenses and depreciation against refund interest.
