Taxing Intelligence: AI's Role in Modern Tax Administration
The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
Impuesto de Timbre: Cuantía indeterminada
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
Impuesto de Timbre, ¿otra vez?
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
Ley Mbappé
Nonprofit Basics: International Grantmaking Part 3 -Special Rules for Private Foundations
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
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 - U.S. Tax Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
Jersey and Guernsey have long been recognised as leading international investment hubs, offering asset managers a compelling mix of professional and lifestyle advantages....more
On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio...more
Introduction - On 15 March 2023, the UK government revealed the widely anticipated Spring Budget, which contained a number of measures that may be of interest to asset managers....more
The government’s 2022 Growth Plan, deceptively referred to as the “mini-budget,” has brought in notable changes likely to impact the funds industry. In particular, a number of the changes will help ensure the continued...more
INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more
On December 22, 2021, the European Commission published proposals for a Directive which targets the perceived misuse of “shell” entities for tax purposes. The draft of the Directive proposes a common minimum substance test...more
The new regime for asset holding companies (the qualifying asset holding company (QAHC) regime) was published last month as part of the draft Finance Bill 2021-22. In essence, the term 'asset holding companies' refers to...more
The UK Government’s public consultation on Asset Holding companies (AHCs) has just finished, having run from December 15, 2020 to February 23, 2021. The objectives of the UK Government in the consultation have been to improve...more
Hong Kong’s private funds industry is on the verge of benefitting from further significant changes in local laws designed to make Hong Kong more attractive as a centre for private funds and their managers. On 31 August 2020,...more
We invite you to join us for a discussion on current tax issues including: • Judicial deference and potential impact on TCJA audits • Developments and planning considerations for intangible assets o US tax...more
The National Constituent Assembly (ANC) on July 2, 2019, issued the constitutional law that created the Wealth Tax (Impuestos a los Grandes Patrimonios). The creation of this tax reopens the debate on the constitutionality of...more
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more
• Significant corporate and potential individual tax rate reductions and a 25% individual tax rate on certain “qualified business income” would be introduced (although many fund investors and sponsors would not be eligible...more