International Tax Issues, Domicile

IRS reduces barriers to redomiciliations

Hogan Lovells on 8/26/2025

On August 19, the IRS released Notice 2025-45 (the “Notice”), announcing its plan to reduce barriers to certain redomiciliations. In particular, the IRS reduced barriers to redomiciliations by foreign publicly traded...more

Guiding Captives Through Global Developments

Conyers on 2/21/2024

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

A Step Forward for a Corporate Re-domiciliation Regime for the UK

Cadwalader, Wickersham & Taft LLP on 5/27/2022

On 12 April 2022, the UK Government published a summary of responses to the consultation on a corporate re-domiciliation regime. We have previously covered the proposed consultation when it was announced as part of the UK...more

Swiss Tax Law Changes: Federal Act on Tax Reform and AHV Financing (TRAF)

Akin Gump Strauss Hauer & Feld LLP on 10/11/2018

• Switzerland’s privileged taxation of companies is no longer in line with international standards. • In 2017, the first attempt to abolish the internationally criticized regime was clearly rejected by Swiss voters. • On 28...more

QDOT-ting I's and Crossing T's: Estate Tax Planning for Non-United States Citizen Spouses

Ward and Smith, P.A. on 4/18/2017

Individual and corporate citizens from countries around the world have moved to North Carolina and contributed materially to our state's economic, educational, and cultural growth. Foreign direct investment ("FDI") in North...more

ATED Returns Are Due in April

McGuireWoods LLP on 2/14/2017

It is that time of year again when we like to draw your attention to the need to prepare and submit your Annual Tax on Enveloped Dwellings (ATED) Returns. By 30 April 2017, you must have completed your ATED Return and...more

Finance Bill 2017 – Implications for Foreign Investment and Investors in the UK

McGuireWoods LLP on 12/7/2016

Following on from the UK Chancellor’s speech last month, draft legislation was published on 5 December 2016 setting out how the Government intends to stimulate investment in the UK. The Finance Bill (the Bill) is subject...more

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