White Mucus From Anus Of Cat

Studio Rag. Mario Stefano Ogna
Rag. Mario Stefano Ogna, accountant and auditor
Dr. Louis A. Ogna, auditor


SUBJECT: CIRCULAR TREMONTI B-44E REVENUE AGENCY

this circular to inform our Dear Readers on the explanations given for the application of so-called "Tremonti B" in the Circular 44 of October 27, 2009 Statement of Direction and Revenue Agency Litigation.

FRAMEWORK

The Dl No 1 July 2009 78 converted with amendments into Law No. 3 August 2009 102, better known as "operation summer 2009," to 'Article 5 declassified as "de-taxation of investment in machinery, has introduced a facilitation for the investment, now renamed as" Tremonti TER.
On 27 October, the Internal Revenue Service has provided the first move to try to resolve the many questions of interpretation.

WHAT IS THE ADVANTAGE

The facility consists in 'exclusion from the imposition of income tax amounting to 50% of the value of investments in new machinery and new equipment, including 28 in Division table ATECO 2007, made from July 1, 2009 until June 30, 2010.

MAIN DIFFERENCES WITH PREVIOUS "Tremonti"

Although the enforcement mechanism is similar to that of the so-called "Tremonti bis" and "Tremonti" there are many differences from previous legislation, in particular the new standard differs from previous :
Ø L 'S SUBJECTIVE: applies to all owners of business income (NO SELF-EMPLOYED) already exist, or to start work from 1 July 2009 to June 30, 2010. Can 'be enjoyed even by people who use systems, accounting and simplified.
or the scope OBJECTIVE: Investment only relate

* NEW * NEW MACHINERY EQUIPMENT
division as shown in TABLE 28 ATECOFIN

However
used in the production process, excluding those processed or assembled to obtain products intended for sale.

OR FOR THE MECHANISM OF APPLICATION: Your benefit is determined on the basis of the cost, without importance of the average investment (and disinvestment) of the 5 tax years preceding the execution of the investment, and the same entity.

STAKEHOLDERS

The facility applies to all persons residing in the State, in relation to the productive activities of business income, regardless of legal status, size, or from the productive sector of belonging. For example
allowed facilitation:
- individual business operators ancorché gestita in forma di impresa familiare,

comprese le aziende coniugali;
- società in nome collettivo e in accomandita semplice;
- società di armamento;
- società di fatto che abbiano per oggetto l'esercizio di attività commerciale;
- società consortili a rilevanza sia interna che esterna;
- società a responsabilità limitata, per azioni e in accomandita per azioni;
- società cooperative e di mutua assicurazione;
- enti pubblici e privati, diversi dalle società, nonché i trust aventi per oggetto esclusivo o principale l'esercizio di un'attività commerciale;
- enti pubblici e privati, diversi dalle società, and trusts do not have sole or main object of the exercise of commercial activities, limited to income from commercial activity.
The facility shall also apply to permanent establishments in the State of non-residents.

ACTIVITIES 'INDUSTRIAL RISK

According to paragraph 2 of Article 5 of the decree: "The holders of industrial activities at the risk of accidents, identified pursuant to Legislative Decree No 17 August 1999 334, as amended by Decree Law No. 21.9.2005 238, can take advantage of incentives TREMONTI TER only if it is documented as the fulfillment of the obligations and requirements of the Decree. "

PERSONS EXCLUDED

fall between those excluded:
- professionals and self-employment;
- those who do not produce business income;
- activities hazard industrial accidents that do not certify the 'fulfillment of obligations and requirements of the relevant decrees;
- the natural and ordinary partnerships, in relation to agricultural activity carried out within the limits laid down in Article 32 of the Income Tax Code;
- individuals, with reference to production of self-employment income under Article 53 of the Income Tax Code;
- unincorporated associations formed between individuals for the exercise in association of arts and professions, including lawyers and the companies (risoluz. 118E of 28.5.2003);
- non-commercial entities do not hold business income.

VALIDITY PERIOD 'INVESTMENT

The facilitation work for the investments made from 1 July 2009 to June 30, 2010.

INVESTMENT FACILITIES

are facilitated gli investimenti in
NUOVI MACCHINARI
NUOVE APPARECCHIATURE
COMPRESI NELLA DIVISIONE 28 DELLA TABELLA ATECOFIN (allegata)

In particolare la circolare stabilisce che, sono agevolabili:

· GLI INVESTIMENTI IN ECONOMIA per i quali rilevano i costi imputabili all’investimento (progettazione, manodopera ecc.);
· GLI INVESTIMENTI REALIZZATI MEDIANTE CONTRATTO DI APPALTO A TERZI;
· GLI ACQUISTI DI BENI CON PATTO DI RISERVATO DOMINIO di cui all’art 1523 del codice civile;
· GLI INVESTIMENTI IN LEASING (MA NON PER I BENI ACQUISITI CON IL C.D. LEASING OPERATIVO).

NATURA DEI PROPERTY

contrast to previous versions, the current legislation does not specify the destination or mode of utilization of assets to be invested in the production process.
This suggests that only the processed goods are excluded or assembled for the production of goods for sale (so-called commodity goods).
NEW CONDITION '

from the wording of the rule it follows that it is not for the Concession goods have already been used in any way.
can be facilitated, for example, the machinery on display in showrooms and used only by the dealer for demonstration purposes only (and therefore never became operational) - Circular 4 / e, 18.1.2002 par. 2 - the retailer must issue appropriate supporting documentation.
For goods produced in the economy, also contributes to their achievement when a well used, the facility is still here, where the cost of the item used is not of overriding importance compared to the overall cost.

TERRITORIALITY '

In order to facilitate not detect the fact that the goods are manufactured by Italian or foreign companies.
contrast to previous versions, the current does not expressly provide that the investment should be made in the State, but provides for the withdrawal of subsidy "if the object of investment goods are sold to persons with permanent establishment in countries outside the European Economic Area."
It follows that investments must be made in production facilities in the State, the Member States of the EEC or of the States Parties to the Agreement on the European Economic Area, which also includes Iceland, Liechtenstein and Norway.

USE

of Facility The facility operates within the IRES and income tax purposes - not for IRAP.
It is enjoyable, making a decrease in the tax base of corporate income tax for the period of execution of investment aided. The tax relief
operates independently of the operating result (profit or loss) and therefore helps to determine the outcome even in the presence of an income loss.
The facility can be enjoyed only in the payment of the balance of income tax due for the taxable year of performing investments (therefore has no impact on the calculation of payments).
Basically in the case of companies with the solar year, payments for 2009 will not be able to apply a reduced estimate with the CD system, for 2010 advances must calculate gross of subsidy (it's always nice to check the tendency towards simplification).

additional discounts


Article 5 does not contain a provision for non-cumulation of benefits with other discounts.
This leads us to believe that the facility is combined with other measures except for the provisions relating to these other facilities, (like the assessments that are within the jurisdiction of the bodies which offer) does not provide otherwise.

It is believed the cumulation:
- investment tax credit in disadvantaged areas;
- business research and development tax credit.

The facility can not be combined with the facility due to the cost of upgrading the energy efficiency ex L. 296/2006.

WITHDRAWAL ADVANTAGE


Paragraph 3 of Article 5 stipulates that "The tax incentive may be revoked if the farmer sells to third parties or employ the goods for purposes extraneous to the investment business before second taxable year following the purchase. "
assumptions are made for the waiver because the well facilitated:
is sold to third parties;
is abandoned;
is destined for purposes extraneous to or consumption of the entrepreneur or his family, and when it is given, donated or given to shareholders;
when leasing is not redeemed within the time limits set out in paragraph 3 (before the second taxable year following the completion of the investment);
purchased and then subject to a lease-back transaction is not subsequently redeemed within the period referred to in paragraph 3;
is purchased by contract reserve Failure to resolve the property of the buyer (Article 1526 Civil Code)..

NOT CONSTITUTE GROUNDS FOR REVOCATION
the theft of the property, as evidenced by the complaint to the competent authorities;
the transfer of the asset transfer in the case of company in case of gift or inheritance upon death;
the transfer of property in connection with a merger, division, and transformation affecting the person who made the investment, provided this does not cause the release of goods from the regime of enterprise;
the transfer of property in extraordinary transactions of sales or transfers of business, provided that the good object of investment in productive activity remains soft.

The study is at your disposal for any further clarifications.

E 'welcome this opportunity to extend

Sincerely

Rag. Mario Stefano Ogna

Studio in Milan Via Carlo Farini n. 63 - Tel 2002 6070006 Fax 0039 0039.02.69900389
Studio in Rome - Via Carlo Conti Rossini No.95 - Tel 06 51607681 - Fax 06 51607609 E-MAIL
mariostefano@ogna.net