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Gift planning opportunities for US persons in the UK

In any event, even under current law, the unified exemption amount will automatically decrease to $5 million (plus an inflation adjustment) come January 1, 2026.

Tax consequences of volume ownership

The new concept of “volumes” refers to a geometric space of three dimensions, geographically located at a well-defined place.

Employment tax issues that not-for-profit organisations need to be aware of

There is no tax and NIC applied to purchases made by employees for home-office equipment until 5 April 2022 due to the Coronavirus pandemic.

FOI request reveals HMRC owes millions after landmark 'round the world' case

The follower notice tells P that they may be liable to a penalty of up to 50% of the tax and/or NICs in dispute if they do not amend their return or settle their dispute."

Cyprus Tax Department publishes updated XML Schema for DAC 6 reporting

Once the XML files are completed they should be submitted on the CTD’s electronic government gateway portal (known as Ariadni).

EY fined more than £2m over audit failings

Big Four firm and former partner receive severe reprimands from UK accounting watchdog

Richard LeVine featured in Wall Street Journal article on off-shore tax shelters

Richard adds that in addition to an IRS crackdown, the Treasury Department could seek changes to the Malta treaty.

Middle East & North Africa: Handling transfer pricing disputes in MENA - The shape of water

Against this backdrop, the Middle Eastern economies are battling lower oil prices and budget deficits, which in turn increase the pressure for fiscal receipts.

UK taxpayer prevented from challenging validity of tax enquiry

The Supreme Court, in its judgment, found that the legal concept of ‘estoppel by convention’ applied in this case.

Tax havens meet monopoly power: why national competitiveness harms competition

There is more than one possible answer, but in many countries a “Competitiveness Agenda” holds sway.

Global Legal Insights Corporate Tax 2021: Luxembourg

The Luxembourg Court has also issued several decisions, which addressed challenges by the Luxembourg tax authorities of periods following the entry into force as of 1 January 2015 of the formal ruling procedure.

Third party tax information notices taxpayers have no right to attend hearing

The third party will usually be notified in advance that an application for the issue of a notice is going to be made and will have an opportunity to submit representations regarding the information required.

‘Avatar’ Film Funding Firm Backed by David Beckham, Sacha Baron Cohen Wins $975 Million Tax Avoidance Case Against HMRC

Ingenious therefore created film finance partnership schemes – which funded some of the world’s most successful films

Cryptocurrency and Non-Fungible Tokens: NY Tax Considerations for Fund Managers

Similarly, Crypto’s status as intangible property under NYS guidance means that it should not be subject to sales and use tax.

‘Lacklustre’ R&D expenditure statistics a cause for concern, says tax expert

Significant focus should be given to how R&D tax reliefs can be used to further encourage and incentivise R&D investment.

Updates to the Singapore-Indonesia Tax Treaty

The updated Singapore–Indonesia DTA that was signed by the respective representatives of Singapore and Indonesia on 4 February 2020 has been ratified by Indonesia on 11 May 2021 and entered into force on 23 July 2021 in Singapore.

The Revenue Rule in the Cayman Islands and British Virgin Islands

It is also well established in other international financial centres and British Overseas Territories, such as Bermuda2.

French tax: Inpatriates regime provides tax exemptions

This includes employees and directors who are posted or made available as part of an intra-group transfer, for instance, from a foreign parent company to a subsidiary based in France.

ESC B18: limitations to the tax credit available for UK beneficiaries of non-UK resident trusts

As for UK resident beneficiaries of non-UK resident trusts

UK proposes new tax regime for fund asset holding companies

The government issued a second consultation on the proposals in December and has now set out the plans for reform in draft legislation, a policy paper and a consultation response document.