Canadian Tax Foundation I Fondation canadienne de fiscalité’s Post

When NESARA rolls out, some of the changes are Stop income tax, unconstitutional IRS and fed banks gone Institute a nation sales tax somewhere between 14 to 17 % on new items only. No tax on food or medicine Fed reserve currency gone no value fake money , return to our treasury notes back by precious metals. Illegal courts gone, they use unconstitutional maritime law on the land. We return to constitutional law, common law. All judges and lawyers have to retrained in constitutional law. Actually all judges and lawyers that are BAR attorneys are in violation of the real 13th amendment. They swear fealty to the British crown and are acting as agents of a foreign power. under our original 13 amendment, they would stripped of American citizenship and deported. Act of 1871 when congress sold America to the luciferian global banksters, our 13th amendment was changed. BAR means British Accreditation Registry.

𝐒𝐂 𝐑𝐞𝐬𝐞𝐫𝐯𝐞𝐬 𝐃𝐞𝐜𝐢𝐬𝐢𝐨𝐧 𝐨𝐧 𝐑𝐞𝐭𝐫𝐨𝐬𝐩𝐞𝐜𝐭𝐢𝐯𝐞 𝐄𝐟𝐟𝐞𝐜𝐭 𝐨𝐟 𝐌𝐢𝐧𝐞𝐫𝐚𝐥 𝐓𝐚𝐱 𝐑𝐮𝐥𝐢𝐧𝐠 | 𝐁𝐢𝐠𝐌𝐢𝐧𝐭 𝐔𝐩𝐝𝐚𝐭𝐞𝐬 The Supreme Court has reserved its decision on mineral taxes. The Centre questions if states' power to tax minerals should apply retrospectively. This ruling could heavily impact industries, with SAIL estimating a ₹3000 crore burden. 𝐒𝐭𝐚𝐲 𝐭𝐮𝐧𝐞𝐝 𝐟𝐨𝐫 𝐦𝐨𝐫𝐞 𝐬𝐮𝐜𝐡 𝐮𝐩𝐝𝐚𝐭𝐞𝐬! #bigmintupdates #royaltynottax #keepingyouahead #MMDRact #Mineralrightscase #steelmarket

State's power to tax mines and minerals: Judgement Explainer 25 July2024 & Nine-judge bench reserves verdict on prospective application of mineral taxation judgement 31 July2024

The full bench of the Australian Federal Court has found in favour of the ATO in a significant transfer pricing case. The case concerned an intra-group loan, the terms of which were amended. The court agreed with the tax authority that the loan was vendor finance, not a debt capital market transaction, and should be priced as such using the arm's length principle, including consideration of the nature of the parent guarantee. Full text of the judgment below. It is not yet know if a final appeal will be made to the High Court #transferpricing #australiantax

Royalty is not tax: Supreme Court allows states to levy minerals cess Cites fiscal federalism to highlight power of states to tax 👉 https://mybs.in/2dXThZ2 #SupremeCourt #Royalty #MineralsCess #FiscalFederalism #StateTaxation #LegalUpdate #IndiaJudiciary #MineralRoyalties #TaxPolicy

The Upper Tribunal decision of 25.09.2024 in Chifley Holdings Ltd (BVI) deals with valuation issues for the Annual Tax on Enveloped Dwellings; ATED. It looks at the relevance of post-valuation date 'comparable' evidence (yes they can be of help) and also the use of index for adjustments to allow for the dates of comparable transactions to capture general changes in the market. There is discussion of the value of properties per square foot. It is an ATED case but could be of relevance for other taxes, including Stamp Duty Land Tax where market value transactions (such as property exchanges, partnership transactions and acquisitions by connected companies) also refer to the same statutory provisions for valuations: TCGA92 s272. FA03 s118 for SDLT applies TCGA92 s272, as does FA13 s98(8) and s102(1) for the purposes of ATED, as referred to in the Chifley case.

Interesting read

The nine-judge Constitution Bench of the Supreme Court of India, with a decisive 8:1 majority, has ruled on the contentious issue of mineral taxation, overturning previous judgments and clarifying the balance of power between the Union and the States. The majority verdict declared that royalty on minerals is not a tax but a contractual consideration, and consequently States have the legislative power to tax mineral rights and mineral-bearing lands over and above the collection of royalty under Mines and Minerals (Development and Regulation) Act 1957 (MMDR Act). To encapsulate on this, our Partner Gopal Krishna Mundhra authors an article on "𝗝𝘂𝗱𝗴𝗲𝗺𝗲𝗻𝘁 𝘁𝗵𝗮𝘁 𝘄𝗶𝗹𝗹 𝗮𝗹𝘁𝗲𝗿 𝗯𝗼𝘁𝗵 𝗳𝗲𝗱𝗲𝗿𝗮𝗹 𝗮𝗻𝗱 𝗺𝗶𝗻𝗲𝗿𝗮𝗹 𝘁𝗮𝘅 𝗹𝗮𝗻𝗱𝘀𝗰𝗮𝗽𝗲" published by moneycontrol.com. Read the article here: https://lnkd.in/dVjH3s9H #ELPinsights #minerals #tax #Landscape #federal #legislative #royalty

This ruling, while allowing retrospective collection up to April 2005 could have some financial impact on the mineral industry and related sectors. However, the decision reduces the potential for severe disruption. The staggered approach as suggested, to payment and a shorter retrospective span, will help ensure that any resulting price increases are more gradual and controlled, balancing the financial recovery for states with the operational stability for companies and minimizing the inflationary ripple effect on the economy. #SupremeCourt #CJI #FinancialImpact #MineralIndustry #RetrospectiveCollection #EconomicStability #OperationalContinuity #PriceControl #StateRecovery #IndustryStability #InflationControl #Manharjitsingh #Law https://lnkd.in/gCsYYVrr

#taxtreatyinterpretations The decision of the Supreme Administrative Court of France is important considering that the Court has applied the tax treaty taking into account the substance of the transaction instead of the legal form. In the Italian case of SICOT Limited, the Italian Supreme Court discussed the interplay between various articles dealing with immovable property /business income and held that if the taxpayer is in the business of purchase and sale of immovable property, Article 7 of the tax treaty dealing with business profits governs taxability of such income and neither Article 6 dealing with income from immovable property nor Article 13 dealing with capital gains would govern such cases. It is therefore important to note that the characterisation of income is essential to determine the appropriate taxing rights both under domestic tax law and tax treaties and such characterisation should be governed by the substance of the transaction and not by the legal form. #taxtreaty #treatyinterpretations #characterisation #courts #france #Italy #dtaa #internationaltax #crossborder #capitalgains #immovableproperty