Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
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
For Bermuda-based entities which have a financial year end of 31 December 2024, the final quarter of the fiscal year is a good time to consider their position with respect to Economic Substance. Economic Substance Regime -...more
With effect from 30 June 2021 the International Tax Co-operation (Economic Substance) (Amendment) of Schedule Regulations, 2021 serve to expand the application of the International Tax Cooperation (Economic Substance) Act...more
The deadline set by the Cayman Islands Department for International Tax Cooperation (“DITC”) for filings by relevant entities that carry on intellectual property business (“IP Companies”) and entities claiming tax residency...more
Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more