5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
The Demystification of Employee Retention Credits for Private Equity Deals — PE Pathways Podcast
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
What is Reverse Vesting and What are the Tax Considerations?
What's the Best Transaction Structure for My Sale?
Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
GILTI Conscience Podcast | Spotlight Series: Carving Your Path in Transfer Pricing
Migration, redomiciliation, continuation - the process which has many names is increasing in popularity. Guernsey has experienced a notable increase in the inward migration of corporate vehicles from other jurisdictions....more
Introduction - Cyprus is an EU member state and a common law jurisdiction with a legal system similar to that of the UK. It is located at the eastern end of Europe linking 3 continents, Europe, Africa and Asia and it has...more
Geopolitical risk is high on the list of challenges that insurance groups have to navigate. There are a variety of reasons it may become necessary for a group to exit a particular jurisdiction, and a multitude of ways an exit...more
As we gear up for the final quarter of 2024, this is an excellent time to review Cayman based entities with a financial year end of 31 December 2024 and consider the position of these entities with respect to the Cayman...more
Q1 How should businesses and individuals prepare for and respond to new governments across the world? Governments play a pivotal role in shaping the financial landscape by imposing regulations, setting corporate and...more
Following Jersey's intention to implement the OECD proposals for a 15% global minimum tax rate (known as "Pillar 2") in May 2024, draft legislation has now been lodged introducing a new standalone Multinational Corporate...more
The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more
The Georgia General Assembly passed several significant tax bills during the 2024 legislative session. Among them was the creation of a tax court in the judicial branch, a reduction of the individual and corporate income tax...more
The Biden Administration’s new corporate tax increase proposal will face substantial challenges in both branches of Congress this year. The IRS continues to focus on the tax profiles of large corporations, limited...more
In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more
Bermuda has announced that it is considering the implementation of a new corporate income tax regime to be effective on or after January 1, 2025, in response to the OECD’s BEPS Pillar II global minimum tax rules. The...more
On 12 January 2023 the Spanish Ministry of Finance published a draft of its long-awaited list of non-cooperative jurisdictions. Spain has finally not followed the EU approach with some jurisdictions. The draft Spanish list...more
Under the German Corporate Income Tax Act (Sec. 32 para. 1 no. 2 German Corporate Income Tax Act, KStG), in the case of dividend payments, non-EU pension funds—unlike local pension funds—do not have the right to claim a...more
The Bermuda Registrar of Companies (RoC) has advised that it will be launching the first phase of its new company registry system on 7 June 2021. Economic Substance Declarations that have been started must be finished and...more
The global impact of the novel coronavirus (COVID-19) is leading to unprecedented changes in working practices. In particular, travel restrictions and, in many cases, border closures are already causing, and will continue to...more
‘Corporate reorganisation’ is something of an umbrella term, and is used in many different contexts to mean a multitude of different things. At one extreme, a reorganisation may refer to ‘paper’ changes to a corporate group’s...more
Traditionally, in the world of international tax planning, it has not been uncommon to see corporate structures utilizing entities organized in offshore jurisdictions that do not impose an income tax on corporate earnings –...more
On September 16, the Organisation of Economic Co-operation and Development (OECD) published a set of recommendations for a coordinated approach to fight tax avoidance by multinational enterprises under the Base Erosion and...more
In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more
Nexus — whether a corporation has a sufficient connection such that it may be taxed by a state — is one of the most important issues in state tax. Various legal theories have been asserted (and are being asserted) to justify...more
The state, of course, likes to see corporations pay their taxes. When a corporation fails to do so, “the corporate powers, rights and privileges of a domestic taxpayer may be suspended, and the exercise of the corporate...more