The Chinese Tax Authority issued a new policy on accelerated depreciation of fixed assets to promote technology innovation and economic development in China (Circular 75).  This policy expands the scope of fixed assets that are eligible for accelerated depreciation methods for corporate income tax (CIT) deduction purposes.  This new policy allows manufacturing companies to accelerate cash flow through shorter fixed asset depreciation periods and encourages increased manufacturing investments in specific industries.

The new policy outlines key conditions for the accelerated depreciation and lump sum methods depreciation. Overall, the new policy will not change the total tax deduction of fixed assets investments.  However, it can benefit start-up or middle-sized enterprises in the early stages of development through increasing after-tax cash flows. The rules encourage six specific high-technology industries, including: 

  • Biopharmaceutical industry
  • Manufacturing of special machinery
  • Manufacturing of transportation equipment for the railway, shipping, aviation, and aerospace industries
  • Manufacturing of computers, telecommunications, or other electronic devices
  • Manufacturing of instruments and meters
  • Information transmission, software, and information technology services

Manufacturing companies that are planning to acquire additional equipment in China are encouraged to contact us to review their financial investment plans to determine if they can benefit from this new tax deduction policy. Please contact us for additional information.


The United States and Canada recently announced an initiative to track individuals crossing the border for both work and for personal reasons. The initiative will track the number of days a resident of one country works or stays in the other country during a calendar year. The foreign individual will have their days in Canada or the U.S. tracked beginning when they cross the border. Once they cross the border back into their resident country, the tracking of their days will complete. The goal of the initiative is to track what foreign companies should be remitting withholding and payroll taxes to the Internal Revenue Service (IRS) or Canadian Revenue Authority (CRA) and to track the tax implications on individuals.

The general rule in the U.S. and Canada is that if an individual is in either country for 183 days or more, the person will be taxed as a resident of that country. Residency determines how and where certain portions of income can be taxed. For example, the United States taxes residents on a worldwide basis and requires residents to file certain informational reporting returns. If a Canadian citizen were found to be spending 183 days or more in the U.S., that person may be subject to the U.S. taxation of their worldwide income and would also be subject to the filing of certain informational returns. As the initiative will track the days spent in a country, the IRS and CRA will now have data available to them on where an individual should be considered a resident for tax purposes. The U.S./Canada tax treaty also provides certain “tie breaker” rules to resolve residency issues where an individual may be considered a resident of both countries under their respective domestic provisions.

Canada also generally requires a 15 percent withholding tax on payments (or wages sourced to Canada) to employees of foreign firms who work temporarily in Canada. The burden is on the foreign firm to file the necessary forms and withhold the necessary tax to remit to the CRA. This is done on an individual by individual basis. An individual may not ultimately be subject to Canadian tax, but it is the foreign firm’s responsibility to remit the necessary withholding tax on any wages or payments that result from services in Canada, unless an advance payroll tax waiver is obtained from the CRA prior to the individual performing work in Canada.

If you or your company is currently sending individuals into the U.S. or Canada, please contact us for more information.


China Tax Authority – Outbound Payments Under the Spotlight

November 13, 2014

The Chinese tax authorities have enhanced their efforts to monitor intra-group outbound service payments and royalty charges. In July 2014, the highest tax authority in China, the State Administration of Taxation (SAT), released the “Notice of Anti-Avoidance Examination on Significant Outbound Payments.” In this notice, the SAT instructs the local tax bureaus to launch comprehensive […]

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Straight Talk on Inversions

October 31, 2014

The corporate structuring transaction known as an “inversion” has been front and center recently regarding U.S. corporate tax policy. Corporate inversions typically involve the acquisition of a U.S. corporation by a foreign corporation, during which the U.S. corporation’s shareholders acquire a majority interest in the “acquiring” foreign corporation. The transaction benefits corporate groups that earn […]

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Straight Talk on Inversions

October 10, 2014

The corporate structuring transaction known as an “inversion” has been front and center recently regarding U.S. corporate tax policy. Corporate inversions typically involve the acquisition of a U.S. corporation by a foreign corporation, during which the U.S. corporation’s shareholders acquire a majority interest in the “acquiring” foreign corporation. Read more at If you have […]

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Additional Guidance Related to Preparation of the Report of Foreign Bank and Financial Accounts (Form 114)

September 5, 2014

The foreign bank and financial account reporting rules require anyone with signature authority over a reportable foreign bank account to complete and file Form 114. Many times, an entity that has a reportable foreign bank account will have an employee that has signature authority over the foreign account. Such employees are required to submit their […]

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Importance of Post‐Merger Integration

July 17, 2014

“Going global” is one of the key focuses for many companies nowadays. Accordingly, cross-border mergers and acquisitions (M&A) has been on the rise, and the trend is expected to continue. Considering post‐merger integration (PMI) plans during the M&A process is as important as considering purchase pricing and financial risks. PMI encompasses everything from financial reporting […]

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IRS Announces Revisions to Its Offshore Voluntary Disclosure Program

July 2, 2014

Oops! The IRS Did It Again! OVDP-2014 Announced The IRS does not seem to be able to leave well enough alone for more than a year or two at a time.  While the last change, in 2012, is only a couple of years old, the IRS announced new revisions that took effect on July 1, […]

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2014 Double Eagle Awards Dinner

May 22, 2014

Each year the U.S.-Mexico Chamber of Commerce hosts a Double Eagle Awards Dinner. The purpose of this dinner is to honor a group of private sector companies and a public sector individual with its Double Eagle Awards. The award criteria are based on a company’s commitment and initiatives to build a stronger relationship between the […]

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Pushing Down Expenses: Are you Minimizing Your Worldwide Effective Tax Rate?

February 24, 2014

There are many strategies that internationally active U.S. companies can exercise to minimize their worldwide effective tax rates. One such strategy is to be diligent about charging out expenses to your foreign branches and foreign flow-through entities. For illustration purposes, think of the very popular business structure of a U.S. company that has a “check […]

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