Successful CSS preparation requires a detailed analysis of the direct and indirect construction, improvement and renovation costs, followed by an examination of available drawings and specifications.
Finally, successful CSS preparation demands detailed knowledge of the tax code as it applies to the cost segregation process.
Business profits: As with several other treaties with developing nations, a limited force-of-attraction rule provides that profits from the sale of goods or merchandise or other business activities carried on by a resident of one CS in the other CS of the same kind as those sold or carried on by a PE in the other CS may be attributed to that PE and taxed in the other CS.
Capital gains: In general, gains or income derived by a resident of a CS from the alienation of immovable (real) property situated in the other CS may be taxed in that other CS.
Pensions: Individuals who render dependent personal services in one CS and contribute to a recognized pension scheme in the other CS can deduct the contributions in determining their taxable income in the first CS; the contributions are treated in the first CS in the same way and subject to the same conditions and limits that ordinarily apply to contributions to the first CS's pension scheme.
55) The 5% rate is available only if: (1) during part of the payer's tax year that preceded the dividend and the whole prior tax year, the payee owned at least 50% of the payer's voting shares, either alone or in association with no more than three other companies of the same CS, provided that each owned at least 10% and (2) no more than 25% of the payer's gross income, other than a company in the principal business of making loans, is derived from interest and dividends from nonsubsidiaries.
promotes accessibility in a number of ways, without compromising design.
With Corda's CSS
Solution, customers can plan, design and implement a customized dashboard system that delivers strategic insight, agility and cost savings.
Laboratories engineering designers use the latest technology trends to develop innovative product offerings and services.
Secure computing, including protection of data and access control, is becoming more important for our enterprise and government customers," said Edward Chiu, president, CSS
Available as a standalone system, DTS-CSS
incorporates elements of DTS' digital sound technology, enabling a single inventory of prints and the appropriate CSS
discs to provide subtitling, captioning and audio description in any required language or languages throughout the world.
Groundbreaking Agreement With LTC Will Leverage CSS