06/05/2023
It also clarifies the tax treatment of trusts with respect to both income and capital gains produced by trust assets and the tax treatment of distributions made to beneficiaries.
06/05/2023
Mr Dines was a 'shrewd' (in the judge's words) businessman but 'hopelessly disorganised' with his paperwork – leading to a bitter fight between his children and second wife in Court over properties worth more than £1m.
06/01/2023
For mid-market companies, HMRC is often a significant creditor, and following its experience in Houst, it was keen to resist being crammed down again.
05/31/2023
An SAYE plan offers eligible employees the opportunity to acquire shares in their employer, or parent, company on a tax-advantaged basis.
05/22/2023
The Islands will monitor implementation internationally and adapt their implementation of the tax rate accordingly to global developments.
05/22/2023
These may be Irish real estate loans or corporate loans of a multinational secured over the real estate of the group including Irish land or buildings.
05/22/2023
There is no arguing that this regime is of financial benefit to remittance basis taxpayers.
05/10/2023
The proposals are not only targeted at retail investors, they are also potentially relevant to institutions such as pension funds and insurance companies as well as other investor categories, such as certified high net worth investors.
04/25/2023
An investment fund must meet several conditions to qualify for the safe harbour
04/24/2023
It is therefore not surprising that one may be tempted to delay any non-essential parts of the move.
04/24/2023
The Amendments further recognize that up to 25% of the FIHV and the ESF Office may be owned by a charitable entity that is exempt from tax under section 88 of the IRO.
04/21/2023
The legislation to implement the Scheme, the Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Bill 2022 (the “Bill”) was gazetted on 9 December 2022.
04/19/2023
This chapter first appeared in the fifth edition of The Corporate Tax Planning Law Review published by Law Business Research.
04/18/2023
As it relates to claims made under Rule 2, the recent amendments to the BVI Guidance Notes provide that where an entity's tax residency is Jersey, Guernsey or the Isle of Man, to claim tax residency there under Rule 2
04/18/2023
The judgment is a welcome and long-awaited confirmation of the scope of the lucrative interest tax regime and relevant for all kinds of leveraged investments, such as carried interest, sweet equity and similar regimes.
04/11/2023
Making the wrong move can have significant consequences, and in the UK, HMRC has demonstrated in recent years that no one is beyond reach.
04/06/2023
In a previous briefing note, we discussed the licensing requirements for family offices under the Securities and Futures Ordinance in Hong Kong.
03/31/2023
A permanent extension of the £1 million annual investment allowance (AIA) was also announced by the chancellor at the Spring Budget.
03/27/2023
With most legislatures in session, Scarborough and Dobay have a lively conversation, touching on the key state and local tax legislative items state policy makers are currently considering as well as a few they are not.
03/27/2023
The question before the Court of Appeal arose from an application from HMRC to the First-tier Tax Tribunal (FTT) for a direction permitting them to disclose to Bell information and documents.