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Corporate Governance International Tax Issues

Walkers

Channel Islands a strategic hub for employee share incentive plans

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In today’s competitive business environment, share incentive plans continue to be a popular tool for aligning employee interests with those of management and shareholders. Guernsey and Jersey, as leading offshore financial...more

Hone Maxwell

Why Some International Entrepreneurs Use U.S. LLCs Without Paying U.S. Tax

Hone Maxwell on

In the increasingly global world of online business, it’s not unusual for entrepreneurs, freelancers, and consultants to seek a business structure that supports international operations, offers stable banking options, and...more

Conyers

Economic Substance Declaration Filings – May 2025

Conyers on

The Economic Substance Act 2018 (the “Act”) requires Bermuda-based entities that are carrying on a “relevant activity” in a relevant financial period and entities claiming “non-resident entity” status under the Act to file an...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Consults on Draft Legislation on Transfer Pricing, Permanent Establishments and Diverted Profits Tax

On 28 April 2025, HM Revenue and Customs (HMRC) proposed significant reforms to the UK’s transfer pricing and permanent establishment (PE) rules, and a repeal of the diverted profits tax, bringing that regime within UK...more

Allen Barron, Inc.

International Business Dealings Require Integrated Legal, Tax and Accounting Support

Allen Barron, Inc. on

Why do international business dealings require integrated legal, tax, and accounting services? It doesn't matter how small or large your company is. If you are a U.S. company that conducts business outside of the United...more

DLA Piper

El Servicio de Impuestos Internos Publica su Catálogo de Esquemas Tributarios 2025

DLA Piper on

Cada año, el Servicio de Impuestos Internos (SII) actualiza la guía denominada Catálogo de Esquemas Tributarios, que contiene un listado de operaciones que pueden ser declaradas elusivas por aplicación de la Norma General...more

Mayer Brown

Positionnement du Gouvernement devant le Parlement lors de lexamen a venir du nouveau projet de loi de finances pour 2025

Mayer Brown on

1.  CONTEXTE - Après la motion de censure du 4 décembre 2024 ayant entraîné le rejet du projet de loi de finances pour 2025, les discussions sur le projet avaient cessé....more

Walkers

The Alphabet Trust and its benefits for South African families

Walkers on

As wealth management evolves, South African high-net-worth individuals ("HNWIs") are increasingly looking for efficient offshore structures to protect and grow their assets. One such option is "The Alphabet Trust" -...more

Mayer Brown

Siège de direction effective : la recherche de la substance de l'entreprise et du lieu de prise de décision stratégique

Mayer Brown on

La cour administrative d'appel de Paris vient remettre en cause la localisation du siège de direction effective d'une société localisée au Royaume-Uni en recherchant le lieu effectif de prise de décisions stratégiques et en...more

McDermott Will & Schulte

Global Equity Plan Reporting Obligations for Calendar-Year 2025: Part One

Global equity plans are complex, and administration requires collaboration between various departments, including legal, human resources, payroll, and tax. Plan administrators (and their teams) should be aware of their...more

Proskauer - Tax Talks

UK Supreme Court confirms no deduction for expenses related to share and asset sale

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On 16 July 2024, the UK Supreme Court (SC) published its judgment in the case of Centrica Overseas Holdings Ltd (COHL) v HMRC. The ruling addresses the issue of whether professional advisory fees incurred in contemplation of...more

Conyers

BVI Quarterly Corporate Update Q1 2024

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Welcome to the first edition of our Quarterly Corporate Update for 2024 covering recent developments in the British Virgin Islands. The first quarter of 2024 saw continued strong activity in the BVI office. Our corporate...more

Skadden, Arps, Slate, Meagher & Flom LLP

Newly Proposed Regulations on Stock Buyback Excise Tax Largely Adopt Approach From Initial IRS Guidance

On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more

Conyers

Guiding Captives Through Global Developments

Conyers on

Bermuda formed the first modern captive in 1962 and remains the leading offshore captive domicile, with approximately 700 licenced captives on its register. Bermuda’s captive industry has remained resilient in the face of...more

J.S. Held

The Diverted Profits Tax & Royalty Withholding Tax: Impacts on Intellectual Property Licenses and Transactions

J.S. Held on

The Diverted Profits Tax (DPT) has been a significant area of focus for taxpayers and tax authorities in the UK and Australia. The tax targets specific situations in which taxable profits are alleged to have been “diverted”...more

Conyers

British Virgin Islands Removed from EU Tax Blacklist

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Following a meeting of the Council of the European Union on 17 October 2023, the British Virgin Islands (“BVI”) was removed from the EU list of non-cooperative jurisdictions for tax purposes (Annex I), the EU’s so-called...more

White & Case LLP

The HMRC Restructuring Plan Challenges: Lessons Learned from GAS, Nasmyth and Prezzo

White & Case LLP on

Earlier this year, the English Court refused to sanction two Part 26A restructuring plans ("RPs") which sought to bind HMRC, the UK tax authority, into restructurings via "cross-class cram down". (See "Restructuring Plans...more

Hogan Lovells

Doing business in Italy 2023

Hogan Lovells on

This booklet has been written specifically for business individuals and whilst it may be of interest to their local advisers, such as lawyers or accountants, the information is intended for a wider audience. We cover topics...more

Hogan Lovells

UK government plans to introduce a re-domiciliation regime

Hogan Lovells on

On 27 October 2021, HM Treasury, BEIS and HMRC published a consultation paper seeking views on proposals for a UK re-domiciliation regime under which foreign-incorporated companies could change their place of incorporation to...more

K&L Gates LLP

Doing Business in the United States

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Companies operating in the United States encounter numerous legal and regulatory issues arising from doing business in the world’s largest economy. Anticipating and dealing appropriately with those issues can improve markedly...more

Jones Day

China Further Opens its Market with New "Foreign Investment Law"

Jones Day on

The Situation: The new PRC Foreign Investment Law ("FIL"), as well as its Implementing Regulations ("Implementing Regulations"), took effect on January 1, 2020. In addition to the FIL and the Implementing Regulations, the...more

Proskauer Rose LLP

UK Tax Round Up - June 2019

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Guernsey SPV not resident in the UK - In Development Securities plc and others v HMRC, the Upper Tribunal (UT) has overturned the prior discussion of the First-tier Tribunal (FTT) in favour of the taxpayer in an important...more

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