Territorial tax system – Atlantic Storm http://atlantic-storm.org/ Thu, 13 Jan 2022 11:17:08 +0000 en-US hourly 1 https://wordpress.org/?v=5.8 https://atlantic-storm.org/wp-content/uploads/2021/05/cropped-icon-32x32.png Territorial tax system – Atlantic Storm http://atlantic-storm.org/ 32 32 Amid Omicron crash, Quebec to crack down on unvaccinated people with new health tax – Red Deer Advocate https://atlantic-storm.org/amid-omicron-crash-quebec-to-crack-down-on-unvaccinated-people-with-new-health-tax-red-deer-advocate/ Thu, 13 Jan 2022 01:50:00 +0000 https://atlantic-storm.org/amid-omicron-crash-quebec-to-crack-down-on-unvaccinated-people-with-new-health-tax-red-deer-advocate/

As infections fueled by the Omicron variant threaten to overwhelm Canada’s health care system, the Quebec government on Tuesday took unprecedented action by promising to tax adult residents who refuse to be vaccinated against COVID-19.

Premier François Legault made the announcement as the province reported another daily record of virus-related hospitalizations. Of the 2,742 hospital patients in Quebec with COVID-19, 255 of them were in intensive care.

The prime minister said the unvaccinated should be forced to pay for the burden they place on the health system, noting that half of people in intensive care are not vaccinated – even though this group comprises 10% of the adult population. The tax would not apply to people benefiting from a medical exemption.

Meanwhile, Ontario reported 3,220 hospitalizations on Tuesday, with 477 intensive care patients, including 250 on ventilators. The Ontario Hospital Association confirmed that 80 adults had been admitted to hospital the day before – the highest number of admissions to date during the pandemic.

The accelerated spread of Omicron has resulted in staff shortages across Canada, affecting hospitals, long-term care facilities and other essential services. As a result, elective surgeries in Ontario have also been suspended, affecting up to 10,000 scheduled procedures each week.

Ontario Health Minister Christine Elliott has announced that to address staff shortages, internationally trained nurses will be allowed to work in hospitals, long-term care homes and other facilities Ontario Health Center.

After Ontario Premier Doug Ford confirmed Monday evening that students would return to class on January 17, Elliott was repeatedly asked to explain which health indicators had changed since last week to allow for the recovery. in-person learning.

“We have done everything possible to make our schools safe for our students,” she told a press conference, adding that all students would receive three-ply masks.

“We are taking all possible measures to make sure our schools are safe for our children…. We needed a little more time to put these provisions in place.

Karen Brown, president of the Elementary Teachers’ Federation of Ontario, said while many teachers want to resume in-person learning, some are concerned about inadequate security measures.

“What they have announced so far is not enough,” said Brown. “We are almost two years into this pandemic. Why do we always ask these things? “

In Ottawa, Prime Minister Justin Trudeau pledged that provinces will have enough COVID-19 vaccines to provide eligible people with a fourth dose, should it become necessary. Trudeau made the pledge in a statement Monday night after speaking with provincial and territorial leaders, saying Ottawa will do everything possible to help them deal with the fifth wave of the pandemic.

“(Premiers) have expressed concern over the pressure on health systems, businesses, workers and families across the country,” the statement said.

In New Brunswick, doctors were treating a record 88 people hospitalized with COVID-19, including 14 in intensive care. Mathieu Chalifoux, the province’s chief epidemiologist, said hospitalizations could jump to 200 if current trends continue.

“We are at the start of a very high tidal wave,” said John Dornan, interim president of the province’s Horizon Health Network. “It’s skyrocketing now, but in the next two or three weeks it’s going to crush us like nobody’s business. “

Coronavirus

]]> Comparison of cross-border tax systems in Europe, 2021 https://atlantic-storm.org/comparison-of-cross-border-tax-systems-in-europe-2021/ Tue, 11 Jan 2022 11:46:03 +0000 https://atlantic-storm.org/comparison-of-cross-border-tax-systems-in-europe-2021/

Today’s map examines the ranking of European OECD countries in cross-border tax rules and is the last in our series examining each of the five components of our International tax competitiveness index (ITCI). Cross-border tax rules define how income earned abroad and by foreign entities is taxed domestically, making it an important part of each country’s tax code.

the ITCIThe component on cross-border tax rules compares various aspects of cross-border tax systems in OECD countries, namely territoriality, withholding taxes, tax treaties and cross-border tax regulations such as the rules on controlled foreign companies ( SEC) and thin capitalization rules.

Territoriality defines the extent to which dividends and capital gains earned abroad are included in the national tax base. Tax treaties align many tax laws between two countries and attempt to reduce double taxation, in part by reducing or eliminating withholding taxes on dividends, interest and royalties received by foreign individuals and businesses. The CFC and thin capitalization rules aim to prevent multinational companies from minimizing their tax liability through base erosion and profit shifting.

The UK cross-border tax system ranks first among OECD countries. Like most OECD countries, the UK operates a territorial tax system, fully exempting foreign dividends and capital gains from domestic tax. The UK has the largest network of tax treaties in the OECD, with around 130 countries. As a result, under the tax treaty, foreign entities from these countries are not subject to 20% withholding tax on interest and royalties received in the UK or pay a reduced rate. There is no withholding tax on dividends. The UK has relatively strict CFC rules and thin capitalization rules.

Among the European OECD countries, Slovakia has the least competitive cross-border tax system (Chile ranks last in the OECD). While Slovakia excludes dividends earned abroad and capital gains from its national tax base, it levies a relatively high withholding tax of 35% on dividends (interest and royalties are subject to a 19% withholding tax). Slovakia’s tax treaty network consists of around 70 countries, and its CFC and thin capitalization rules are relatively strict.

Click here to view an interactive version of the ranking of cross-border tax rules for OECD countries, then click on your country for more information on the strengths and weaknesses of its tax system and how it compares to the top and bottom five OECD countries.

To see if the ranking of your country’s cross-border tax rules has improved in recent years, check the table below. To learn more about how we determined these rankings, read our full methodology here.

Cross-border tax rule component of the International tax competitiveness index between 2019 and 2021 (for all OECD countries)
OECD countries Ranking 2019 Ranking 2020 Ranking 2021 Change from 2020 to 2021
Australia (AU) 25 24 24 0
Austria (AT) 5 5 seven -2
Belgium (BE) 9 18 18 0
Canada (CA) 16 16 16 0
Chile (CL) 37 37 37 0
Colombia (CO) 36 35 35 0
Czech Republic (CZ) 12 12 12 0
Denmark (DK) 28 30 30 0
Estonia (EE) 15 15 15 0
Finland (FI) 21 21 21 0
France (FR) 17 13 13 0
Germany (DE) seven seven 6 1
Greece (GR) 29 25 25 0
Hungary (HU) 4 4 4 0
Iceland (IS) 30 31 31 0
Ireland (IE) 19 19 19 0
Israel (IL) 13 ten ten 0
Italy (IT) 26 27 26 1
Japan (JP) 20 26 27 -1
Korea (KR) 33 33 33 0
Latvia (LV) ten 9 9 0
Lithuania (LT) 24 23 23 0
Luxembourg (LU) 6 6 5 1
Mexico (MX) 35 36 36 0
Netherlands (NL) 2 3 3 0
New Zealand (NZ) 23 22 22 0
Norway (NO) 11 11 11 0
Poland (PL) 27 29 29 0
Portugal (PT) 31 28 28 0
Slovak Republic (SK) 34 34 34 0
Slovenia (SI) 22 20 20 0
Spain (ES) 18 17 17 0
Sweden (SE) 14 14 14 0
Switzerland (CH) 3 2 2 0
Turkey (TR) 8 8 8 0
United Kingdom (GB) 1 1 1 0

Source: International tax competitiveness index 2021.

Launch our International tax competitiveness index

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Bosnian Serbs Hold Nationalist Celebration Despite Ban and Sanctions | News https://atlantic-storm.org/bosnian-serbs-hold-nationalist-celebration-despite-ban-and-sanctions-news/ Sun, 09 Jan 2022 16:33:14 +0000 https://atlantic-storm.org/bosnian-serbs-hold-nationalist-celebration-despite-ban-and-sanctions-news/

The Bosnian Constitutional Court declared the holiday illegal because it discriminates against Bosnian Muslim and Croatian Catholic communities.

The Bosnian Serbs staged public celebrations to mark the national day of their Autonomous Serbian Republic, defying a supreme tribunal’s ban on commemoration and US sanctions imposed on their leader Milorad Dodik this week.

The January 9 holiday commemorates the date in 1992 when the Bosnian Serbs declared the establishment of their own state in Bosnia and Herzegovina. He unleashed a devastating war that lasted almost four years and left 100,000 dead.

The date also coincides with a Serbian Orthodox Christian holiday, and it is this religious component that led the Bosnian Constitutional Court to declare the holiday illegal because it discriminated against the Bosnian Muslim and Croatian Catholic communities in the region.

More than 800 armed police, including members of counterterrorism units, gendarmerie and cavalry, took part in the parade on Sunday alongside students, veterans and athletes through the streets of the region’s largest city. , Banja Luka.

Crowds of spectators and demonstrators waved red, blue and white Serbian flags. Members of a special police unit sang songs referring to the Serbian Republic as a state of Christian heritage.

Liljana Smiljanic of Al Jazeera, reporting from Banja Luka, Bosnia, said that if for Serbs the date was “sacred” it meant something completely different for Bosnians.

“They [Bosnian Serbs] say it [January 9 holiday] guarantees them freedom and the best living conditions in Bosnia and Herzegovina. On the other hand, for the Bosnians… this is the beginning of the horrors of war they endured in the 90s, and later of the war crimes and genocide in Srebrenica, ”she added.

Bosnian member of the Tripartite Presidency Milorad Dodik greets people in a parade to mark the national day of their Autonomous Serbian Republic [Antonio Bronic/Reuters]

The parade and other ceremonies were attended by senior officials from neighboring Serbia, including Prime Minister Ana Brnabic and Speaker of Parliament Ivica Dacic. Russian and Chinese diplomats in Bosnia and several officials of the French far-right Rassemblement national party were also present.

There was no sign of the Bosnian Joint Armed Forces Serbian regiment, which had been deployed for the parade in previous years. Instead, the focus was on the militarized police force, which led the parade with specially designed combat vehicles as helicopters flew overhead.

Secessionist ambitions

Dodik, who is currently a Serbian member of the Bosnian interethnic tripartite presidency, said “that there is no freedom for the Serbian people without the state”, in a speech to the crowd watching the parade.

The pro-Russian nationalist has repeatedly threatened to withdraw Serbian representatives from the Bosnian armed forces, tax system and judiciary and to create separate Serbian institutions.

Last Wednesday, he was freshly sanctioned by the United States for corruption and undermining the stability and territorial integrity of Bosnia.

The Dayton Peace Agreement brokered by the United States in 1995 ended three and a half years of ethnic warfare in Bosnia, dividing the Balkan country into two self-governing regions – the Serbian Republic and the Bosnian-dominated Federation and the Croats.

“Everything he does and announces he will do is not in accordance with the constitution of Bosnia and Herzegovina as well as the Dayton Peace Agreement,” said Smijanic of Al Jazeera.

“It’s a base for everything here in this country,” she added.

Dodik’s secessionist rhetoric in recent months has encouraged Serbian nationalists, who in recent days have provoked incidents across the Serbian Republic, shooting in the air near mosques during prayers, publicly praising convicted war criminals and threatening their victims. Muslim neighbors.

He described the Bosnians as “second class people” and “traitorous converts” who sold their “original [Orthodox Christian] faith for dinner ”.

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US imposes new sanctions on Bosnian Serb leader, calling him threat to Balkan “territorial integrity” https://atlantic-storm.org/us-imposes-new-sanctions-on-bosnian-serb-leader-calling-him-threat-to-balkan-territorial-integrity/ Wed, 05 Jan 2022 18:23:40 +0000 https://atlantic-storm.org/us-imposes-new-sanctions-on-bosnian-serb-leader-calling-him-threat-to-balkan-territorial-integrity/

The US Treasury Department said on Wednesday it was imposing additional sanctions against Bosnian Serb leader Milorad Dodik and a media company he would control, Reuters reports.

A Treasury Department statement accused Dodik of “corrupt activities and persistent threats to the stability and territorial integrity” of Bosnia and Herzegovina.

Last month, the lower house of Republika Srpska passed a non-binding resolution that would dissociate the semi-autonomous republic from the fiscal, military and judicial system of Bosnia and Herzegovina.

Dodik, the Serbian member of the three-person interethnic presidency from Bosnia, supported the vote. He is in favor of removing the framework established by the Dayton Accords of 1995, which ended the war that devastated the country following the break-up of the former Yugoslavia. “Bosnia is an experience … I don’t believe it can survive because it doesn’t have the internal capacity to survive,” Dodik said at the time.

Under Dayton, Bosnia and Herzegovina remains a nation but is divided into two enclaves: the ethnically Serbian Republika Srpska and the Ethnically Croatian-Bosnian Federation of Bosnia and Herzegovina. Most government functions are vested in the semi-autonomous governments of these entities. The presidency of the nation must constitutionally be composed of a Serb, a Croat and a Bosnian.

Even before the December vote, Dodik’s rhetoric worried international observers.

“The [Bosnia and Herzegovina] the population is really afraid of another war, noticing the same worrying signs as in the 1990s, ”two left-wing Dutch MEPs in the European Parliament wrote in a November editorial.

MEPs concluded that unless Dodik and his supporters face “the realistic threat of targeted sanctions or some other form of serious international pullback, they will continue to escalate this crisis, which could eventually lead to secession,” thus risking violent conflict “.

Samuel Ramani, Associate Researcher at the Royal United Services Institute for Defense and Security Studies, wrote on Twitter that the new US sanctions were a “sign of growing US assertiveness in Bosnia and a step back against [Russia’s] influence in the Balkans.

Ramani said The week that Dodik and Russian President Vladimir Putin have “a cordial personal relationship” and that Russia “has expressed concern about discrimination against Serbs in Bosnia and Herzegovina”.

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International tax affairs to watch in 2022 https://atlantic-storm.org/international-tax-affairs-to-watch-in-2022/ Mon, 03 Jan 2022 17:02:00 +0000 https://atlantic-storm.org/international-tax-affairs-to-watch-in-2022/
By Natalie Olivo (Jan 3, 2022, 12:02 p.m. EST) – Courts will continue to wrestle this year with high-stakes cases brought by large U.S. multinationals that have accused federal tax authorities of overriding, with disputes, including including FedEx’s challenge to repatriation regulations and Facebook’s fight against multibillion-dollar adjustments to its tax bill.

As the new year unfolds, courts across the country will rule on several closely watched cases in which companies have claimed the Internal Revenue Service and the US Treasury Department have exceeded their authority, in particular when adjusting income or drafting regulations. Facebook, for example, is challenging a transfer pricing adjustment from the IRS, which argued that the tech giant …

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New laws will come into force in Canada in 2022 https://atlantic-storm.org/new-laws-will-come-into-force-in-canada-in-2022/ Sat, 01 Jan 2022 12:00:00 +0000 https://atlantic-storm.org/new-laws-will-come-into-force-in-canada-in-2022/

With 2021 behind us, a number of new rules and regulations are expected to come into effect this year. Some of the changes include increases in the minimum wage, bans on plastic bags and taxes on soft drinks.

Below are some of the new rules and regulations that will come into effect at the federal and provincial levels in 2022:

AT NATIONAL SCALE

Prohibition of conversion therapy

Federal legislation banning conversion therapy received Royal Assent on December 8, but will not come into effect until January 7, 2022, 30 days after the bill comes into force.

The new law will make conversion therapy, a practice that seeks to change a person’s sexual orientation to heterosexual or their gender identity to cisgender, punishable by up to five years in prison. Anyone who promotes, advertises or profits from the implementation of the practice can face up to two years in prison.

Single-use plastics ban

A federal ban on single-use plastics was promised by the end of 2021, but in November the government announced the ban would be postponed until 2022.

The ban includes six single-use plastic items, including checkout bags, cutlery and straws.

End of fossil fuel financing

The federal government announced at COP26 this year that it would halt new direct public funding for coal, oil and gas development by the end of 2022 and redirect that investment towards renewable energy projects.

The United States, United Kingdom and 21 other countries have also joined the pledge.

Changes to carbon tax refunds

Beginning in July, rebates for residents of Alberta, Saskatchewan, Manitoba and Ontario, due to increased carbon pricing costs, will be issued quarterly rather than annually.

BRITISH COLUMBIA

Refund of milk container

In February, containers for milk and milk substitutes join the list of products eligible for a rebate from British Columbia, like cans and bottles.

The province estimates that the program will help it recycle an additional 40 million containers each year.

Paid sick leave

As of January 1, part-time and full-time employees in British Columbia are entitled to five days of paid sick leave.

ALBERTA

Daycare prices go down

In a $ 3.8 billion deal with the federal government, Alberta’s child care costs will be cut in half – on average – starting Jan. 1, with the goal of hitting $ 10 per day in daycare by 2025.

The agreement is also expected to create some 40,000 new spaces for non-profit child care centers in the province.

New area code

Alberta will welcome its fifth area code, 368, on April 23.

The new code will only be issued when the province runs out of numbers on existing area codes and will not affect existing phone users.

SASKATCHEWAN

Mandatory smoke detectors

As of July 1, all residential buildings in Saskatchewan will be required to be equipped with a smoke detector and a carbon monoxide detector.

The law includes buildings with regular dormitories, such as homes, condos, apartments, townhouses, duplexes, motels, and care facilities.

Before the introduction of this law, buildings constructed since 1988 had to be fitted with a fire alarm and buildings constructed since 2009 had to be fitted with a carbon monoxide detector.

MANITOBA

Changes to the investigation of human rights complaints

Beginning January 1, Manitoba will implement changes to the Manitoba Human Rights Commission (MHRC) to allow the department to respond more quickly to human rights complaints.

The changes allow the executive director of the commission to dismiss complaints and deny an investigation of certain complaints, as well as to set deadlines for hearings and decisions.

Under the current system, it can take up to six years to resolve a human rights complaint in Manitoba.

ONTARIO

Increase in minimum wage

Ontario’s minimum wage increases to $ 15 an hour on January 1, which critics say is still not enough to earn a living wage in the province.

Rent increases are back

Ontario’s rent freeze, a measure intended to help residents during the pandemic, is also expected to end on January 1. The provincial government has set a guideline for an increase of 1.2% for 2022.

Ease at the pump?

As gasoline prices hit all-time highs in the province, Ontario Premier Doug Ford has pledged a gasoline tax cut of up to six cents per liter delivered by March 31.

QUEBEC

Changes to the Quebec curriculum

As of the 2022 school year, classes in Quebec will begin teaching “Culture and citizenship in Quebec” instead of the Ethics and Religious Culture program.

The new program is structured around three main components: “culture”, “citizenship in Quebec” and “dialogue and critical thinking”.

The program will be piloted in 2022, before being taught province-wide in 2023.

NEW BRUNSWICK

Changes to Address Youth Vaping

New Brunswick requires all vaping stores to purchase a $ 100 license effective January 4, although it does not apply until April 1.

The province says the licenses will allow for inspections of businesses, increase liability and allow communication in the event of a recall.

Proposed animal protection measures

Although only proposed, New Brunswick also plans to implement additional animal protection measures on January 1.

The new measures include the requirement for all sellers of dogs and cats to provide a valid health certificate to buyers, improved tether standards and the addition of two new standards for animal care: the code of the NBSPCA Dog Care Practice and the Dog Care Code of Practice. and handling rabbits.

NEW SCOTLAND

Amendments to adoption recordings

Nova Scotia is making changes to adoption records that allow adopted children and birth parents to access their adoption records once they turn 19.

The changes will take effect in April.

PRINCE EDWARD ISLAND

Increase in minimum wage

Effective April 1, Prince Edward Island’s minimum wage will drop to $ 13.70 per hour.

The 70-cent increase gives Prince Edward Island the highest minimum wage in Atlantic Canada.

NEWFOUNDLAND AND LABRADOR

Tax on non-alcoholic beverages

Newfoundland and Labrador will introduce a tax of 20 cents per liter on beverages containing added sugars starting in September.

The tax is expected to bring in $ 9 million to the province.

NORTHWEST TERRITORIES

Strengthening the training of new truck drivers

Those looking to get into the truck driving business will need to complete a mandatory entry-level training program to earn their Class 1 license, starting in January.

Previously, new truck drivers only needed to pass a practical and theory exam to receive certification.

YUKON

Ban on single-use plastic bags

As of January 1, single-use plastic shopping bags are banned in the Yukon as part of “initial steps towards a broader single-use plastics ban in the Yukon and reflect feedback received as a result of the pledge. with Yukoners and Yukon businesses, ”according to a news release from the territory.

The territory also plans a ban on single-use paper bags for January 1, 2023.

NUNAVUT

New holidays

Nunavut has not recognized September 30 as the National Day for Truth and Reconciliation, but it will be a territorial holiday in 2022.

In mid-September, the territorial government said it didn’t have enough time this year to officially recognize the holiday, but would be ready to do so in 2022.

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Government of Canada launches demands for expanded Canada Containment Benefit https://atlantic-storm.org/government-of-canada-launches-demands-for-expanded-canada-containment-benefit/ Thu, 30 Dec 2021 21:40:00 +0000 https://atlantic-storm.org/government-of-canada-launches-demands-for-expanded-canada-containment-benefit/

OTTAWA, ON, December 30, 2021 / CNW / – The government of Canada is committed to supporting Canadian workers, businesses and service providers during the COVID-19 pandemic.

At 22 December 2021, the government of Canada announced it would expand eligibility for the Canada Worker Containment Benefit (CWLB) to better support Canadian workers. Today, the Honorable Diane Lebouthillier, Minister of National Revenue, announced that expanded access to the CWLB is now in effect and that Canadians in designated areas affected by eligible closures or capacity restrictions can apply for the benefit. .

Currently, British Columbia, Alberta, Manitoba, Ontario, Quebec, New Brunswick, New Scotland, Prince Edward Island, Newfoundland and Labrador and Nunavut are included in the list of designated locking regions. This list will be updated as provincial or territorial governments make changes to public health restrictions.

The government will continue to ensure that Canadians have the support they need to deal with the impacts associated with the evolving Omicron variant, while supporting a strong economic recovery. Building on the measures included in Bill C-2, the government approved new regulations that:

  • Expand the Canada Containment Benefit for Workers include workers in areas where provincial or territorial governments have introduced or recognized capacity restrictions of 50% or more. This benefit will provide $ 300 a week of income support for eligible workers who are directly affected by a public health lockdown related to COVID-19 and who have lost 50% or more of their income as a result. Affected Canadian workers in the newly designated lockdown regions can apply for the benefit today. Payments will be retroactive to December 19, 2021. To be eligible for the CWLB, you must meet eligibility criteria which include, but are not limited to:
    • You won at least $ 5,000 in 2020, 2021 or in the 12 months preceding the day on which you request the benefit;
    • You have filed a 2020 income tax return;
    • A region in which you work or provide a service is designated as a COVID-19 Lockdown Region during the application period;
    • A designated COVID-19 lockdown in your area resulted in one of the following events during the application period:
      • you lost your job and are unemployed
      • you are self-employed but unable to continue your work
      • you are employed or self-employed but your average weekly income has decreased by at least 50% compared to the previous year.
  • This updated regulation will apply from December 19, 2021, at February 12, 2022.

People who have attempted to apply to the CWLB before noon December 30e in areas not yet designated as eligible by the CRA were asked to call the CRA at 1-800-959-8281 to speak to an agent to finalize their request.

The CRA’s top priority is to continue to ensure that access to COVID-19 benefits is simple and clear, and that benefit payments get to those who need them, as quickly as possible. The CRA will also continue to monitor fraud and suspicious activity and implement the necessary controls to protect program integrity and ensure that only eligible Canadians receive benefit payments.

Quote

“By these measures, the government of Canada making sure Canadian workers affected by regional health measures and lockdowns have the support they need. These changes will ensure Canadians have the support they need to cope with the economic impacts of the Omicron variant, while promoting a strong economic recovery. We are closely monitoring developments and will continue to work with our partners to implement COVID-19 support measures as quickly as possible to address the financial hardship Canadians continue to experience. “

-The Honorable Diane Lebouthillier, Minister of National Revenue

“Since the onset of the COVID-19 pandemic, our government has put Canadians first, providing them with the support they need to stay safe and healthy. Through Bill C-2 and the expanded Canada Worker Containment Benefit, we working Canadians through targeted income support as regions implement public health measures to stop the spread of COVID-19. The government will continue to be there for working Canadians and their families, while ensuring from Canada the economic recovery is leaving no one behind. “

– The Honorable Carla Qualtrough, Minister of Employment, Workforce Development and Disability Inclusion

Related links
Information document
The Canadian Worker Containment Service
Targeting support measures related to COVID-19
COVID-19 Benefits and Services – Canada.ca

Stay logged in

Information document

Since the start of the COVID-19 pandemic, the government of Canada put Canadians first, providing them with the support they need to stay safe and healthy.

Under Bill C-2, the government of Canada introduced the Canada Worker Containment Benefit (CWLB) to provide targeted income support to workers who are unable to work due to containment measures related to COVID-19.

At 22 december, the government of Canada announced that, on a temporary basis from December 19, 2021 at February 12, 2022, COVID-19 public health orders restricting public access to businesses by at least 50% would be included in the definition of a foreclosure order. This means that people who temporarily lose their jobs or experience a 50% or more reduction in income due to a designated COVID-19 lockdown in their area could be eligible for the CWLB.

How jurisdictions are designated as a “lockdown region”

Also from December 19, 2021 at February 12, 2022, provinces, territories and Indigenous communities can issue COVID-19 public health orders and be considered by the government for designation as a “lockdown region.” However, as part of the designation process, those issued by municipalities or public health authorities must be recognized by a provincial / territorial government as meeting the definition below in order to be considered for designation:

  • the closure to the public of premises where persons carry on business or provide services which are not essential to the preservation of life, health, public safety or the basic functioning of society; Where
  • restrictions reducing by at least 50% the maximum number of persons who may enter or occupy premises where persons carry on business or provide services essential or not essential for the preservation of life, health, public safety or the basic functioning of society; Where
  • a requirement, applicable in the region specified in the order, regulation or other instrument, that persons remain at home, except for reasons essential to the preservation of life, health, public safety or basic functioning of society

Fraud prevention and guarantee of eligible candidates.

In order to guarantee people in need quick access to financial assistance, the government of Canada chose to use an attestation-based approach to deliver the CWLB. This means that individuals must self-report the information they provide when submitting a benefit claim. If a person is verified and later declared ineligible, despite being certified to this effect, they will have to reimburse the amounts received. The Canada Revenue Agency (CRA) has zero tolerance for fraud and applicants can expect their information to be verified at the time of application and / or at a later date.

The CRA will continue to monitor fraud and suspicious activity and implement new controls to protect the integrity of the program and ensure that only eligible Canadians receive payments. Protecting the privacy of Canadians is a priority for the CRA, and the trust that individuals have in the CRA is a cornerstone of from Canada tax system.

SOURCE Canada Revenue Agency

For further information: Chris MacMillan, Press Secretary, Office of the Minister of National Revenue, 343-540-6066; Media Relations, Canada Revenue Agency, 613-948-8366, [email protected]

Related links

http://www.cra-arc.gc.ca/

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Educational opportunities in the post-pandemic period https://atlantic-storm.org/educational-opportunities-in-the-post-pandemic-period/ Wed, 29 Dec 2021 16:00:00 +0000 https://atlantic-storm.org/educational-opportunities-in-the-post-pandemic-period/

The education sector must face 2022 with more optimism in anticipation of the end of the pandemic, coupled with the hard lessons learned through it, and guided by the collective vision of a matatag, maginhawa, in panatag na buhay (strongly rooted, comfortable and secure life) in 2040.

The deeply rooted life will be highlighted by the Filipino family who are with members capable of spending time with friends, living a balanced professional life and volunteering in service to communities. A comfortable life should be one that is free from hunger and poverty, living in and owning a secure home, having good transportation, and able to travel and take vacations. A secure life is envisioned as having sufficient resources for daily needs, unforeseen expenses and savings; enjoy the peace and security, and live a long, healthy life towards a comfortable retirement.

By 2040, the Philippines will be a prosperous middle class society where no one is poor. People live long and healthy lives, and are smart and innovative. The country is a trusted society where families thrive in vibrant, culturally diverse and resilient communities.

Ambisyon 2040 began in 2015 and stems from a long-term visioning process guided by an advisory committee made up of government, private sector, academia and civil society and in which more than 300 citizens participated with some 10,000 contributions via a national survey.

The bold Ambisyon 2040 needs an engaged education sector to make it happen. Those born in 2022 will then be of legal age, and we may still have time to embark on an educational revolution before entering our education system in six years, and for the benefit of learners these days. -this.

There have been and still are disruptions giving rise to new and emerging demands that offer educational opportunities. Here are some anticipated and envisioned changes (or wishlists) that lead to educational potentials to be adopted and optimized. These changes are also anchored in realizing the envisioned future for the Philippines and in making Filipinos world citizens of the future and beyond.

Digitization and digital transformation

The government will be forced to migrate fully to digitalization if it is serious in providing an efficient public service and if it is committed to reducing corruption. Taxation, for example, may need to be digitized to simplify complex processes and reduce the human contact that breeds corruption. If the private sector is capable of digitally transforming itself, there is no excuse for the government not to do the same.

In the private sector, e-commerce is being accelerated by the pandemic and the adaptive business processes that have allowed businesses to survive and thrive. Electronic commerce is destined to remain and even to reach proportions and innovations beyond our present imagination. Cryptocurrency and blockchain infrastructures enable a larger crypto economy, making virtual objects redeemable for real economic value.

New generation IT, KPO and electronics

The IT-KPO which reached $ 27 billion in 2020 (compared to $ 9 billion in 2010) is an emerging gold mine in the country. From voice-based Business Process Outsourcing (BPO) services, it has the potential to become the global center of excellence in Knowledge Process Outsourcing (KPO) if only we can transform ourselves in the areas artificial intelligence, robotics and animation, game and software development, cloud technology and information management.

There is an inevitable pursuit of the metaverse, a virtual reality space in which users can interact in a computer-generated environment and other uses. It is an interface of platforms on the Internet that have built interactive worlds complete with virtual entertainment, socialization and business. Crypto-metavers are immersive virtual worlds with immense social and financial potential.

These, and many others, may seem Greek to many, but they are emerging realities that education should be able to understand and optimize, if it is to be part of the future.

Entrepreneurial MSMEs

The government will need to provide more incubation centers for microenterprises, especially those in tech start-ups, social entrepreneurship and sustainable enterprises. Microenterprises (89% of all companies) will benefit from a Microenterprise Commission which will ensure access to finance (money), mentoring and the market; mindset and instructions for entrepreneurship; integrated government and non-government assistance; and tax incentives and reductions.

Entrepreneurial MSMEs include the creative and knowledge industries, which have become a trademark of Filipino products and services. A basic law for the creative industries is imperative, and this should spur educational institutions to take it to the next level.

Education should cultivate entrepreneurial thinking and financial literacy in the early years of training. Incubation centers can be academic institutions linked to government agencies and industries that could offer learning in an authentic, more contextualized setting. Education outcomes need to be co-created by the ‘village’ that is needed to ‘educate a child’.

MSMEs generate 62% of jobs. Education can contribute to the employability of its graduates for the productivity of these MSMEs, to the entrepreneurial graduates who will go into business, and to the partnership it can forge with MSMEs to benefit from research and of development, which is the strength of the university.

The agricultural revolution

There is no need to exaggerate the problems and concerns of the agricultural sector, whose production has only increased by 20% in the space of 10 years. There is a need to allow industrial agriculture, which may prompt the government to review the land use law. The science and technology that has proven to be effective among the countries that were formed on our lands (and from which we import our agricultural supplies nowadays), are the same technology that we could learn to apply. Agricultural budget support must drop from the usual 3% to 8% of our GDP if we really want to achieve food self-sufficiency.

The appreciation of agriculture as a viable career among our youth can benefit from productive agribusiness and other value-added agribusiness enterprises in the value chain. Accelerated rural development will inspire young people to be the most productive as a goal-driven generation in their provinces.

Universal health care

RA 11223 was adopted before the onset of the pandemic. It is anchored on a vision for better health outcomes for Filipinos. This will pose a challenge on building public capacity for care, enlisting the essential participation of the private sector, and on building confidence in the ministry of health to orchestrate the ambitious whole-of-government and l whole system. . With issues of supply preparation, financial constraints and sustainability, the education sector may see opportunities for relevant institutions alongside intergovernmental cooperation.

The availability of the essential human resource, the primary care provider, depends on the ability of academia to provide competent graduates through its programs, who may need to pivot towards greater relevance. To be successful, UHC needs empowered people and communities, which academia can take as its role.

Professionalized governance

The growing number of young voters (estimated at 52% under 40 by Comelec, with 5 million voters for the first time) and the powerful social networks that provide information in real time, there is pressure to professionalize governance . There is an emerging clamor for governance based on rules, science and values. Government technocrats may need to emerge from academia, with values ​​and skills grounded in research.

Ambisyon 2040 can only be achieved through empowered citizens able to ‘review’ candidates, in the same way the electorate may have learned by reviewing even their small online purchases. The education sector may need to play a proactive role, not in influencing decision-making, but in developing critical thinking that would enable its learners to discern biased disinformation in the digital space.

Critical mind

Academia may need to engage its learners in careful thought to take a stand on many issues and dilemmas in a globalized world. He understands the issues of climate change and environmental protection in relation to the God-given Filipino wealth of more than $ 1 trillion in mineral reserves, the equivalent of Saudi Arabia’s oil. We should also engage in a conversation about foreign direct investment (FDI) that we may need to attract to infuse new capital, technology and best practices from the competition it may impose on our local industries, which may have difficulty competing. There is also a dichotomy between the global preference for Filipino knowledge workers who are offered compelling salaries and benefits abroad and our need for their expertise and services to propel our own growth. Our perceived need to break down local oligopolies by opening industries to foreign competition that threatens many comfort zones. Our need to optimize exchanges with China, but with ambivalent paranoia because of its lack of respect for the decision of the Arbitral Tribunal, which is in our favor. The need for multilateral cooperation with democracies around the world for various national interests, but with reservations about how ordinary Juan Dela Cruz might benefit. The need for a credible national security policy with our barely available resources to protect our territorial seas as an archipelago, at least for our food security.

Education has the power to transform young learners into global citizens capable of co-creating a society that we collectively choose to deserve. Ambisyon 2040, if achieved, may no longer be enjoyed by many of us. But surely it will benefit our children and our children’s children in a country which is the only one we have.

No Filipino should lose faith as long as we believe in the Almighty. No Filipino should give up on love, as long as there is reason to live. No Filipino should give up hope while there is education.

Dr Carl Balita is a Doctor of Education, Certified Teacher, Registered Nurse and Midwife. He is a member of the board of directors of the Philippine Franchise Association and chairman of basic education of the Philippine Chamber of Commerce and Industry. He is an award-winning entrepreneur and media personality, author, university professor and trainer. He is a columnist for BusinessMirror, on leave after submitting his certificate of candidacy to the senator.

This document was presented at the swearing-in and investiture ceremony of the Local Colleges and Universities Accreditation Commission.

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Ireland plans to switch to a territorial tax system – MNE Tax https://atlantic-storm.org/ireland-plans-to-switch-to-a-territorial-tax-system-mne-tax/ Thu, 23 Dec 2021 20:26:44 +0000 https://atlantic-storm.org/ireland-plans-to-switch-to-a-territorial-tax-system-mne-tax/

By Doug Connolly, Multinational Corporate Taxation

The Irish Department of Finance opened a public consultation on 22 December seeking comment on a possible transition to a territorial tax regime for companies.

Such a system “could be simpler and offer greater security to businesses – but should also be accompanied by robust anti-abuse measures,” suggests the consultation document.

Ireland currently has a global corporate income tax system under which Irish resident entities are subject to domestic and foreign source income tax. Double taxation relief for foreign taxes paid on foreign source income is provided through credits against domestic tax liability.

The proposed changes would move Ireland from a credit method for relieving double taxation to an exemption method. Ireland is considering adopting a limited territorial regime using a participation exemption or branch exemption approach, as is common among EU member states, as opposed to a fully territorial regime.

The Finance Department asks for feedback on the benefits of switching to such a system, as well as any consequences or indirect risks for multinationals. He further asks if existing exemplary regimes could serve as a model to minimize compliance burdens without increasing the risk of tax evasion.

The consultation lists several possible diet variants. A participation exemption regime could exempt foreign dividends from related parties and income from foreign branches. The variations could include granting a broader participation exemption for earnings, limiting the scheme to dividends paid out of corporate trading profits, or limiting it to trading income from foreign branches.

The participation regime could also be limited to specified categories of jurisdictions, such as tax treaty partners and EU member states, while retaining the global regime for other jurisdictions.

The consultation is seeking feedback on these potential design elements.

The Finance Department is also asking how Ireland’s current Controlled Foreign Companies (SEC) rules would align with a participation or branch exemption scheme and what changes might be needed. Likewise, the government would like to hear from stakeholders on the potential interactions of such a regime with the exit tax and existing anti-hybrid rules in Ireland.

The consultation paper suggests that the changes to the country’s corporate tax regime brought about by the recent OECD tax deal have made it an appropriate time to reassess the country’s approach to corporate tax, in the aim of maintaining the attractiveness of the country as an investment destination. However, the government is also seeking comments on how the global agreement might affect the move to an exemption regime.

Finally, the consultation asks questions about the implications of a transition to a territorial regime for Ireland’s tax treaty network, as well as any necessary transitional arrangements or other considerations that should be taken into account.

The consultation is open until March 7, 2022.

Doug Connolly is editor-in-chief of MNE Tax. He has over 10 years of experience in tax legal developments, previously working with both a Big Four firm and a leading legal publisher. He holds a law degree from the American University Washington College of Law.

Doug Connolly
Doug Connolly
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Malaysia prepares for taxation of foreign source income https://atlantic-storm.org/malaysia-prepares-for-taxation-of-foreign-source-income/ Thu, 23 Dec 2021 08:04:27 +0000 https://atlantic-storm.org/malaysia-prepares-for-taxation-of-foreign-source-income/

As of January 1, 2022, the current exemption from income tax on foreign source income (FSI) received in Malaysia by Malaysian residents will be removed.

This article highlights the impact and practical considerations that businesses and individuals should consider when preparing for the impending tax on the ISP. The content of this article reflects the legislation and FAQs available to the public as of December 20, 2021.

Overview of the existing ISP exemption

Currently, the FSI of anyone received in Malaysia is exempt from income tax, with the exception of Malaysian resident companies engaged in banking, insurance, or air or sea transport. This has not always been the case: the FSI tax exemption was first introduced in 1998 for resident companies to encourage taxpayers with income from abroad to repatriate their income to Malaysia ( except for the few industries mentioned above). In 2004, this FSI exemption was extended to all taxpayers, including individuals.

Imminent taxation of ISPs in Malaysia

When announcing the 2022 budget, the government proposed to remove the tax exemption on ISPs enjoyed by residents of Malaysia with effect from January 1, 2022. This proposal is reflected in the 2021 budget bill, which has was adopted by the House of Representatives but is still being read in the Senate and has not yet been published as law at the time of writing (finance bill).

Under the Finance Bill, ISPs received in Malaysia between January 1, 2022 and June 30, 2022 by all tax residents, including individuals and businesses, will be taxed at 3% on a gross basis. The FSI tax rate received after this period will be the applicable tax rate for individuals and resident companies. The proposal as is covers all forms of income (eg business or employment income, dividends, interest, royalties) and will affect all Malaysian resident taxpayers, regardless of their size or industry.

On November 16, 2021, the Inland Revenue Board of Malaysia announced in a press release that it will be offering a special income disbursement program (Program Khas Peremitan Pendapatan, also known as PKPP) for the period from January 1, 2022 to June 30. 2022, during which ISPs received in Malaysia by taxpayers who declared their participation in the PKPP before July 30, 2022 will not be subject to audits, investigations or sanctions.

On December 17, 2021, the Inland Revenue Board published a PKPP FAQ (PKPP FAQ), which provides that taxpayers can report their participation in the PKPP in an online form through MyTax.

Basis of the change in tax treatment of wealth tax

According to the 2022 Budget Speech, the reasons for the proposal to tax ISPs received in Malaysia by Malaysian residents are to ensure sustainable income for Malaysia and to comply with international tax best practices.

For context, on October 5, 2021, the Council of the European Union included Malaysia in its “gray list” as a jurisdiction that has committed to change its exemption regime “detrimental” to ISPs by now. December 31, 2022. Other jurisdictions like Hong Kong, Costa Rica, Qatar and Uruguay have also been included in the Gray List on the same basis.

Although the Malaysian government is expected to change the existing tax regime to address EU concerns, many had not anticipated the general removal of the FSI exemption for Malaysian residents. This is all the more true given that the EU has clarified in its guidance that ISF exemption regimes are not in themselves problematic and that the concern is over the “double non-taxation” circumstances that can occur. arise with respect to the passive income of a business that has no substance in the country.

Hong Kong, which adopts a source-based tax regime similar to Malaysia’s, announced the same day that the gray list was released that it will continue to adopt the principle of territorial source taxation despite its inclusion. in the gray list. However, to address EU concerns, it will change its legislation by the end of 2022 and the proposed legislative changes will only target businesses (and not individuals) that earn passive income, especially those that do not. no substantial economic activity in Hong Kong.

Malaysia’s immediate neighbor, Singapore, which was not on the gray list, imposes taxes on ISPs while maintaining certain exemptions for certain categories of income (for example, foreign-source dividends, branch profits or corporate income). income from professional, advisory and other services) subject to the fulfillment of the specified conditions. Individuals who are not residents of Singapore are generally exempt from tax on their ISP.

Indonesia recently introduced the Omnibus Law, one of the main amendments being the introduction of a tax exemption for dividends received by Indonesian tax residents from offshore companies, provided that the income is reinvested in Indonesia for a certain period of time. period and other qualifying investment requirements.

The jurisdictions mentioned above seem to consciously adopt tax policies in a targeted manner to ensure that they remain attractive for investment, while balancing other considerations such as the need to maintain a sound tax base and the character. defensible tax system under international law. meticulous examination.

Likewise, in an era of globalization and increased international scrutiny of the tax regimes of each jurisdiction, the challenge for Malaysia would be to respond to international tax concerns with a focused and measured approach, in order to remain competitive on the scene. global as an attractive jurisdiction. for investments and business operations.

Considerations for Malaysian Residents

Removal of the FSI exemption for Malaysian residents will mean that FSIs such as dividends distributed by foreign companies, interest from foreign loans granted outside Malaysia or foreign bonds, rental income from real estate located outside Malaysia, and even employment income earned by Malaysian tax residents outside Malaysia will be subject to Malaysian income tax when received in Malaysia on or after January 1 2022.

Below we summarize the main issues Malaysian residents should consider when considering the implications of this new tax development.

  • Definition of “receipt”

ISPs that are not received in Malaysia will not be taxed. The Budget Bill and Malaysia’s Income Tax Act (ITA) currently do not specify the definition of “receipt”. As a result, on the sole basis of legislation, there is uncertainty as to whether certain transactions, such as contra transactions between related entities or the settlement of a debt incurred in respect of a company in Malaysia, could potentially be considered received in Malaysia.

However, the Inland Revenue Board recently clarified in the PKPP FAQ that only income remitted, imported or transferred to Malaysia from (i) physically, or (ii) through the banking system, will be considered “received” income. in Malaysia. In light of this, it appears that contra transactions may not be counted, but the transfer of funds in Malaysia to a creditor in settlement of a debt can potentially be counted.

Since the meaning of “receipt” is crucial in determining whether a tax is owed under the ISP, this clarification is welcome.

  • Distinction between income and capital

ISP tax will only affect a receipt that is “income” in nature. Capital gains remain outside the scope of income tax under the ITA, even if they are from a foreign source and subsequently received in Malaysia. This was also confirmed by the Inland Revenue Board in the PKPP FAQ.

Resident taxpayers will need to determine whether their receipt qualifies as income or capital based on all of the circumstances and factors surrounding the receipt. Specific types of revenue such as dividends, royalties, and interest will generally fall under the income category.

From a practical standpoint, it will be difficult for taxpayers to prove the nature of a receipt to the satisfaction of the Inland Revenue Board, especially if the receipt in Malaysia is from funds that have been kept outside Malaysia. for a longer period.

Going forward, taxpayers will need to be more diligent in keeping records of their earnings (both income and capital) and money transfers to and from Malaysia.

ISFs received in Malaysia may have already been taxed elsewhere. To combat double taxation of the same income, the ITA provides relief in the form of (i) bilateral tax credits, when the relevant foreign country in which the tax was paid has a Double Taxation Agreement (DTA) with Malaysia; or (ii) unilateral tax credits, where the relevant foreign country in which the tax was paid does not have a DTA with Malaysia.

Based on the PKPP FAQ, these credits must be claimed for the FSI received in Malaysia within two years of the end of the relevant valuation year in which the FSI is reported. Taxpayers are required to keep proof of foreign taxes that have been paid under the FSI.

In practice, it will be difficult for resident taxpayers to prove that tax has been paid in the foreign jurisdiction with respect to the amount that is remitted in Malaysia, especially if the amount remitted comes from funds that have been kept out. of Malaysia for a number of years.

Taxpayers should begin to compile and prepare supporting documentation proving that foreign taxes have been paid on the income they plan to remit as an ISP in Malaysia after January 1, 2022, to ensure that any claim for tax credit can be justified.

Going forward, taxpayers will need to continue to keep similar supporting documents for their ISPs.

Applying for tax credits can be administratively burdensome for resident taxpayers, especially individuals. It remains to be seen whether the Inland Revenue Board will be able to reduce administrative challenges for taxpayers by simplifying how to claim tax credits.

The PKPP FAQs suggest that existing income tax reporting forms will be updated to include a new line for taxpayers to report the amount of FSI received in Malaysia from tax year 2022. Taxpayers should stay within the scope of tax. ” keep an eye out for developments regarding reporting obligations, to ensure that they comply with any new rules.

Conclusion

Although the effective date of the removal of the ISP exemption is fast approaching, some uncertainty remains from a technical and administrative point of view.

In these final days leading up to the New Year, it will be important for individuals and businesses residing in Malaysia to take a closer look at their financial affairs, assess potential tax risks, and plan ahead to ensure that ‘they are in the best position to face the tax challenges ahead.

This column does not necessarily reflect the opinion of the Bureau of National Affairs, Inc. or its owners.

Author Info

Yvonne Beh is a partner and Irene Khor is a partner at Wong & Partners, a member firm of Baker McKenzie in Malaysia.

The authors can be contacted at: yvonne.beh@wongpartners.com; irene.khor@wongpartners.com

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