News & Analysis as of

Business Entities Taxation

Dickinson Wright

Tax Planning Misstep? Ontario Court of Appeal Says No to Rectification

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A recent decision from the Ontario Court of Appeal is a good reminder that courts won’t bail you out just because a tax plan didn’t go as expected. In Pyxis Real Estate Equities Inc. v. Canada, 2025 ONCA 65, the Court made it...more

Walkers

Overview of the Cayman Islands Economic Substance requirements

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Each entity incorporated, established or registered in the Cayman Islands must file an annual economic substance notification with the Tax Information Authority (the "TIA"). A "relevant entity" conducting "relevant...more

Dickinson Wright

Tax Considerations in Analyzing Offers from Practice Groups

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Although in prior articles in this publication, I addressed tax issues faced by physicians and other practice groups, the purpose of this article is to guide physicians and other medical professionals as they compare the...more

Mayer Brown

Quote-part de benefices perçue d une SCCV et taxe sur les salaires

Mayer Brown on

Le Conseil d’État juge que les quotes-parts de bénéfices perçues par une société dans des sociétés civiles doivent être traitées comme des produits financiers non soumis à la TVA, remettant en cause l’exonération de taxe sur...more

Mayer Brown

Qualification de titres acquis lors d’une augmentation de capital suivie d’une cession

Mayer Brown on

La Cour administrative d’appel de Nancy confirme que la moins-value constatée lors de la cession de titres souscrits dans le cadre d’une recapitalisation préalable à la cession d’une filiale reste non déductible, ces titres...more

Morrison & Foerster LLP

Re-domiciling Companies to Hong Kong

From May 23, 2025, companies may transfer their domicile to Hong Kong under a new regime which will allow them to preserve their legal identity and will not interrupt business operations. To qualify, companies must meet...more

DLA Piper

Deductibility of Consultancy Fees Upheld by Supreme Administrative Court

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On 26 May 2025, the Swedish Supreme Administrative Court ruled in favour of OneMed Sverige AB regarding the deductibility of consultancy fees and input VAT. OneMed had reimbursed its parent company for consulting services...more

Carey Olsen

Why the Cayman Islands continues to be a popular jurisdiction for offshore funds

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Over the past 25 years, the Cayman Islands have established themselves as a leading jurisdiction for alternative investment funds, with nearly 13,000 regulated open-ended funds and over 17,000 regulated closed-ended funds. As...more

Clark Hill PLC

When does a converted entity or a merged entity need a new Employer Identification Number from the IRS?

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What is an EIN? An EIN is a federal tax ID number for an entity, estate, trust, or other organization. For example, the following are generally required to obtain an EIN: partnerships, limited liability companies (“LLC”),...more

Rivkin Radler LLP

State Taxation of a Nonresident’s Gain from the Sale of Stock –The Shot Heard Round the Country?

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Last month, Bloomberg carried an article about a “small but growing trend” of states that are either cutting their individual income taxes or phasing them out entirely. According to the article, the states adopting these...more

Warner Norcross + Judd

Buying a Yacht? Navigating the Legal Waters

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The purchase of a yacht is a significant financial investment that requires navigation of a multitude of legal issues. Consultation regarding these issues, as well as tax, liability protection and venue location, should all...more

Allen Barron, Inc.

What is an Integrated Business Services Partner?

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What is an integrated business services partner, and why is the integration of these important areas of expertise essential to your company's success?...more

Mayer Brown

Evaluation des titres de sociétés et libéralité entre sociétés liées

Mayer Brown on

Dans un arrêt du 6 mars 2025, la Cour administrative d'appel de Bordeaux s'est prononcée sur la méthode mathématique d'évaluation de titres de SCI utilisée par l'administration, ainsi que sur la caractérisation d'une...more

Allen Barron, Inc.

The Trend to Integrate Legal, Tax, Accounting, Business and Financial Advisory Services: the KPMG Arizona Gambit

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It has always been prudent to search for firms who can integrate legal, tax, accounting and business advisory services. While there are few such genuine providers across the United States they do exist, and the KPMG Arizona...more

Rivkin Radler LLP

New York Sales Tax: When a Responsible Person Acts Irresponsibly

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Late last year, the Office of the State Comptroller (the “OSC”) estimated that sales and use tax receipts would increase by 2.3% in the SFY 2024-2025. The OSC also projected that collections from sales and use taxes would...more

McDermott Will & Emery

Exit tax for investement shares

McDermott Will & Emery on

Anyone who moves out of Germany and has investment shares or transfers them outside of Germany will have to pay taxes – even if the shares are not sold. Private investors in investment funds will have to pay taxes in the...more

Conyers

Why BVI?

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The British Virgin Islands (“BVI”) are home to 361,491 active companies as of 31 December 2023. This article considers the reasons for the BVI’s popularity as a jurisdiction to structure international transactions....more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Verrill

Private Clients Group Client Alert

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There have been a few important law and tax changes over the course of 2023 and we in the Private Clients Group here at Verrill wanted to make you aware of the recent changes, such as 1) new strict corporate reporting...more

Hogan Lovells

Round-up: Indonesia

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Round-up: Indonesia is our new quarterly newsletter, rounding up all the latest legal updates and events in Jakarta. ...more

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