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Modern U.S. Treaties: Taxpayers Must Meet the Limitation on Benefits Articles - ECOVIS International

Modern U.S. Treaties: Taxpayers Must Meet the Limitation on Benefits Articles

Generally, tax treaties between two countries provide lower withholding tax rates on income generated by persons of one country in another country. The withholding tax rates provided by a tax treaty may differ on case-by-case basis depending on the parties...
An Exception to the Mirror Image - ECOVIS International

An Exception to the Mirror Image

Income on One Side of a Debt Transaction Does Not Always Produce Loss on the Other A mirror image is usually reflected in the tax impacts for the two parties to a debt instrument transaction. When the holder recognizes interest...
Entities holding foreign securities (ETVE) in Spain - ECOVIS International

Entities holding foreign securities (ETVE) in Spain

An opportunity to fiscally optimize the multinationals investments. ETVEs (“entities holding foreign securities”) were created in Spain in 1995 as another way to attract foreign investment, specifically to promote the establishment in Spain of holding entities which, based on the...
Transformation of payroll management services in Mexico - ECOVIS International

Transformation of payroll management services in Mexico

Recent changes in Mexican Labor and Tax Laws, related to the restrictions in engagement of personnel services (outsourcing banning) entitles an important business opportunity for consultancy Firms, since there are a lot of companies currently looking for support in implementation...
The “Great Resignation” – What do the workers want? - ECOVIS International

The “Great Resignation” – What do the workers want?

I wonder if you might have heard about “The Great Resignation”. This phenomenon apparently has happened because of the pandemic by covid-19 and it is about the massive quitting by workers around the world.  I hope this newsletter might show...
M&A transaction with Belgian parent company to an company in Hungary with US subsidiary - ECOVIS International

M&A transaction with Belgian parent company to an company in Hungary with US subsidiary

Background We were contacted by an in-house attorney of a multi-national company based in Belgium regarding corporate/M&A legal services in the United States. The client provides technology solutions for a variety of applications, including energy storage and testing, automated systems,...
The four most relevant pillars for good corporate governance - ECOVIS International

The four most relevant pillars for good corporate governance

Hand in hand with globalization, the concept of Corporate Governance has been implemented in an accelerated manner, understanding that it is undoubtedly a tool for competitiveness, where the objective is to ensure the proper management and administration of companies, protect...
What is inflation? - ECOVIS International

What is inflation?

Inflation and deflation are economics terms used to describe an increase or decrease in the value of money, relative to the amount of goods and services that money can buy. Financially, inflation is the reduction in the value of the...
E-invoicing in Guatemala: Companies must act now - ECOVIS International

E-invoicing in Guatemala: Companies must act now

From 1 January 2023, companies in Guatemala will only be able to issue e-invoices. This is the only way tax documents may be issued from this date. (more…)
Controlling Beneficiaries - ECOVIS International

Controlling Beneficiaries

Validity As of January 1, 2022 Legal Basis Articles 32-B Ter, 32-B Quater and 32-B Quinquies of the Federal Tax Code (CFF) in correlation with rules 2.8.1.20 to 2.8.1.23 of Miscellaneous Tax Resolution 2022 (RMF) and articles 84- M and...
Navigating Foreign Pension Plans - ECOVIS International

Navigating Foreign Pension Plans

Pension plans are a common investment tool for individuals. The reporting requirements for most U.S. pension plans are straightforward; however, foreign pension plans may have additional filing requirements that are not readily apparent. The individual owners of foreign pension plans...
The Evolution of Management - ECOVIS International

The Evolution of Management

After more than 30 years of experience in accounting and auditing, I have heard countless recurring complaints from people who need to make timely financial decisions. Chief among the complaints, I often hear, “To prepare for a meeting of my...
Tax efficient transfer of U.S. real estate to U.S. recipients - ECOVIS International

Tax efficient transfer of U.S. real estate to U.S. recipients

The U.S. tax system imposes an estate tax on non-U.S. residents who die while owning U.S. assets. An exemption of $60,000 is available to non-U.S. residents to lower the U.S. estate tax base. U.S. estate tax is levied on the...
Relevant aspects of the 2022 miscellaneous tax resolution (RMF) in relation to the simplified trust regime for individuals (RESICO PF) - ECOVIS International

Relevant aspects of the 2022 miscellaneous tax resolution (RMF) in relation to the simplified trust regime for individuals (RESICO PF)

On December 27, 2021, the RMF 2022 was published in the Official Gazette of the Federation (DOF) which is effective as of January 1, 2022 (except in cases where a different date is indicated). Below are some of the most...
U.S. Tax Reform: International in the cross-hairs  - ECOVIS International

U.S. Tax Reform: International in the cross-hairs 

U.S. businesses still interpreting 2017 tax legislation will soon need to respond to Biden Administration proposals to fund ambitious plans to rebuild infrastructure and assist families. In 2017, the U.S. tax base was expanded to include worldwide income through the...
Reform to NGO Law: Guatemala - ECOVIS International

Reform to NGO Law: Guatemala

In Guatemala, the legislation on non-profit entities has not been so severe, so the authorities considered it appropriate to start the supervision and control in a strategic way based on good practices, always respecting constitutional rights, as well as the...
The Evolution of Management - ECOVIS International

The Evolution of Management

What I am about to narrate to you is the result of more than thirty years of experience in financial information analysis from the perspective of accounting, auditing, and the constant recurring complaints of people who need to make timely...
COVID-19 Implications to Business Groups - ECOVIS International

COVID-19 Implications to Business Groups

As a result of the COVID 19 health emergency, compliance with the market value principle becomes an important challenge for Business Groups, given the economic impacts that has been generated in most industries around the world during fiscal years 2020-2021...
COVID-19 Paid Leave Tax Credits – An Update - ECOVIS International

COVID-19 Paid Leave Tax Credits – An Update

The Families First Coronavirus Response Act (the “FFCRA”), enacted by Congress on March 18, 2020, required most employers to provide employees with paid leave in certain situations connected with the COVID-19 pandemic (the “FFCRA Mandate”). To offset the cost of...
International Quality Standards for Auditors: Uruguay - ECOVIS International

International Quality Standards for Auditors: Uruguay

The International Quality Control Standard 1 (ISQC) deals with the responsibilities that an audit firm has in relation to its quality control system of its assignments, whether they are audits, review of financial statements and other assignments related to granting...
Simplification of Administrative Procedures in Guatemala - ECOVIS International

Simplification of Administrative Procedures in Guatemala

The proposal or initiative of Law 5766 for the simplification of requirements for administrative procedures that we hope will be published in May 2021 follows the same philosophy that the most advanced economies in the region have implemented in the...
VAT on foreign services rendered - ECOVIS International

VAT on foreign services rendered

Those who provide services from abroad to residents in Colombia, as a general rule, will have the legal obligation to register with the Colombian tax authority as "service providers from abroad", in addition to passing on and collecting VAT on...
Audit considerations during Covid-19 - ECOVIS International

Audit considerations during Covid-19

Recently the IFAC (International Federation of Accountants), International Federation of Accountants in Spanish, issued certain considerations related to the safe audit of financial statements in times of Covid-19. These are situations that matter to the auditors but also to those...
Mexico Tax Reform 2021 - ECOVIS International

Mexico Tax Reform 2021

For the Tax Reform of the 2021 fiscal year, the Executive presented on September 8, 2020, to the Congress of the Union, the respective Economic Package, which includes proposals for the fiscal Miscellaneous regarding the Income Tax Law (LISR ),...
Presidential Elections, Tax Chaos - ECOVIS International

Presidential Elections, Tax Chaos

The upcoming U.S. election on November 3 will not only seat a President for the next four years, it will also establish which party controls both houses of the U.S. Congress, and with control, the ability of the President and...
The Pareto Principle - ECOVIS International

The Pareto Principle

Let's do an Audit with Pareto Principle. Nowadays, time is conceived as a limited resource and, insofar as it is managed efficiently, it can become an investment rather than an expense, resulting in the generation of returns and tangible value....
Audit in a health emergency - ECOVIS International

Audit in a health emergency

The worldwide health emergency situation, and particularly in Uruguay, has affected practically all activities. The auditors' work is no exception. During an audit, auditors must (to meet the objective of being able to issue an opinion on the reasonable presentation...
Mitigating the impact of GILTI - ECOVIS International

Mitigating the impact of GILTI

Section 962 Election, U.S. Blocker Corporation, or Check-the-box? The Tax Cuts and Jobs Act (TCJA) of 2017 introduced a new IRC section 951A, which requires a United States Shareholder (U.S. Shareholder) of a Controlled Foreign Corporation (CFC) to include for...
Digital Tax: Chile - ECOVIS International

Digital Tax: Chile

Law 21210 of February 24, 2020 in its article 35 A of the new paragraph 7 bis of the Law on Sales and Services Tax establishes that taxpayers not domiciled or residing in Chile that render services taxed according to...
Use of data analysis for auditing - ECOVIS International

Use of data analysis for auditing

Reality or fiction? It is the beginning of a new year which leads to reflection and goal setting. As auditing professionals, it is important to question performance and how to keep improving in the vocation, which makes us wonder: is...
Modifications to the tax system in Paraguay - ECOVIS International

Modifications to the tax system in Paraguay

According to official data, Paraguay has a total population of 6,873,496 inhabitants. From this total, the total Economically Active Population (PEA) is 3,465,976, which corresponds to approximately 50% of the total population. As of December 31, 2019, the total number...
Market development of the cannabis in Peru - ECOVIS International

Market development of the cannabis in Peru

It has been three years since the incident which altered the perception and use of Cannabis in Peru. It is important to conduct an analysis of the current situation, both inside and outside of the country, in order to take...
Foreign Tax Credits and Various Operating Structures - ECOVIS International

Foreign Tax Credits and Various Operating Structures

For U.S. companies undergoing international expansion, there are a number of important issues to consider prior to commencing operations in a foreign jurisdiction. A principal consideration is the type of foreign entity through which the U.S. company will be conducting...
Investment projects in the Mexican energy sector - ECOVIS International

Investment projects in the Mexican energy sector

The Federal Government has promoted the construction of new infrastructure and the improvement of the existing one in the energy sector, seeking to turn the country into a world-class logistics platform, promoting a balanced regional development, as well as sustainable...
Tax treatment of a non-residential alien - ECOVIS International

Tax treatment of a non-residential alien

Letʼs start by discussing, in general terms, how the U.S. taxes a nonresident alien. A foreign national who has neither a green card nor satisfies the Substantial Presence Test is considered to be a “U.S. nonresident.” As a U.S. nonresident,...
New international standards in auditing - ECOVIS International

New international standards in auditing

The main changes to the International Standards on Auditing (ISA) were not superficial, since they include reforms designed to significantly improve audit reports for investors and other users of financial statements (banks, shareholders, customers, suppliers, the government sector, etc.). In...
Digital transformation at a glance - ECOVIS International

Digital transformation at a glance

Digital transformation is changing entire organizations as it opens the doors for many opportunities. Numerous market forces are driving the need for digital transformation. Many companies have embarked on complex digital transformation journeys, encompassing all aspects of their business to...
Panama: a former tax haven - ECOVIS International

Panama: a former tax haven

On March 13, 2019, after intense analysis and dialogue, the finance ministers from the European Union removed Panama from the list of “tax haven” countries. This means that Panama is no longer categorized under the list of countries labelled “non...
Canada: the great white north - ECOVIS International

Canada: the great white north

Canada has been a very attractive country for foreign investment for a long time. There are many reasons for this including, a very stable political system, successive governments that encourage foreign investments, a stable banking system that weathered the financial...