News & Analysis as of

Domicile

Montana Enacts Captive Insurance Law Impacting Reciprocal And Dormant Insurers

by Carlton Fields on

On May 4, 2017 Montana enacted a new law that will remove the requirement that reciprocal captive insurers have 25 or more persons domiciled in Montana. The law also permits captive insurers to go into dormancy. The...more

Despite Clash Over Tax Cuts, Governor Dayton Signs Bill Enacting Important Income Tax Changes for Minnesota Residents and...

by Dorsey & Whitney LLP on

On May 30, 2017, Governor Dayton signed into law Minnesota’s omnibus tax bill (HF 1), which contains significant income tax changes of interest to both residents and nonresidents of Minnesota. Initially, Governor Dayton...more

Home Is (Not) Where Your Legal and Financial Advisers Are: Minnesota Changes Domicile Determinations

by Faegre Baker Daniels on

Minnesota will no longer consider the location of a person’s attorney, CPA, financial adviser or bank account when determining where an individual is domiciled for income tax purposes. Under Minnesota law, an individual is...more

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

by Ward and Smith, P.A. on

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

MoFo New York Tax Insights - Volume 8, Issue 4

by Morrison & Foerster LLP on

ALJ Finds CEO Changed Domicile from New York City to Texas - A New York State Administrative Law Judge has held that the CEO of Match.com (“Match”) changed his domicile from New York to Texas for New York State and City...more

A Quiet UK Budget for Asset Managers, But Other Recent Tax Changes Shouldn’t Be Forgotten

by Proskauer - Tax Talks on

After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK...more

Florida Department Of Revenue Issues Advisement Determining That A Reinsurer And Its Cedents Did Not Have Nexus In Florida For Tax...

by Carlton Fields on

On January 13, 2017, the Florida Department of Revenue issued a Technical Assistance Advisement regarding whether a reinsurer had nexus with the state of Florida that would require it to file a corporate income tax return and...more

Changing Your “Home” For State Tax Purposes – Not So Easy

by Farrell Fritz, P.C. on

It’s February, the middle of winter, and many of us are longing for warmer weather. Some with second homes in Florida or Arizona and the like start thinking about changing their primary residence for state income and estate...more

Snowbird? Or the real deal?

by Farrell Fritz, P.C. on

So you recently moved from New York to Florida? Abundant sunshine, no income tax, no estate tax — wonderful! One problem: New York State tax authorities may not think you really moved! And they’re assessing heavy income...more

ATED Returns Are Due in April

by McGuireWoods LLP on

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

Non-Domicile Changes in the United Kingdom From April 2017 – Are You Ready?

by McGuireWoods LLP on

Sweeping changes being introduced in the United Kingdom for non-domiciles (non-doms) will take effect from 6 April 2017. These changes are significant and will affect all non-doms. Our recommendation is that non-doms review...more

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

by McGuireWoods LLP on

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

Singapore Legal Update - November/December 2016

by Allen & Overy LLP on

Companies Act to Allow Re-domiciliation Into Singapore - On 26 October 2016, the MOF and the ACRA proposed to amend the Companies Act to allow for inward re-domiciliation of companies. This will allow a foreign company...more

Confirmation of Non Dom Changes in the UK Autumn Statement

by McDermott Will & Emery on

New UK Chancellor Philip Hammond gave his first Autumn Statement on 23 November 2016. Whilst there were no further details relating to the reforms of the taxation of non-UK domiciliaries and UK residential property, the...more

The Implications of the Expanded Scope of the French Class Action System on Potential Liability and Insurance Coverage for...

by Reed Smith on

Although the French class action system has gotten off to a slow start with only 6 actions initiated to date, the recently and anticipated expanded scope of the French class action system will impact the potential liability...more

The Mental Capacity Needed To Change Domicile

by Bryan Cave on

In litigation, domicile matters because it can control where a lawsuit must be filed and fought. For most of us, where we are domiciled should be straightforward. It’s the place where we actually live and intend to remain. ...more

2016 New York Tax Update: Highlights and Lowlights

by Hodgson Russ LLP on

There wasn’t much in the way of substantive New York tax changes in the 2017 budget bill that Governor Andrew Cuomo signed in April. Or at least wasn’t much in the way of changes that affect the day-to-day practices of the...more

IRS to Update 1967 Revenue Ruling Relating to Change of Domicile

The Internal Revenue Service (the “IRS”) has announced plans to update Revenue Ruling 67-390, which requires an organization to “re-apply” for tax-exemption if it changes its corporate structure, including in situations...more

U.S. Citizens Retiring Abroad: “Tax Trigger” Situations and Related Disclosure Forms

The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax...more

Further Changes Announced to the Non-Domiciles Regime

by McGuireWoods LLP on

On 19 August 2016, the UK Government published a new consultation paper together with draft legislation which will affect changes to the non-domiciles (“non-doms”) regime in the UK. The proposals will be legislated...more

Non-Dom Reforms Update – United Kingdom

by McDermott Will & Emery on

Summary - Following the United Kingdom’s vote to leave the European Union on 23 June, and the change of Prime Minister and to the UK Government, there was significant uncertainty regarding what would happen to the...more

T&E Litigation Newsletter- July 2016 #2

by Goulston & Storrs PC on

The first two weeks of July have brought us some warm weather and three new decisions worth noting: First, in Bank of America, N.A. v. Commissioner of Revenue, Docket No. SJC-11995 (July 11, 2016), the Supreme Judicial...more

Brexit's Impact on the Insurance Industry

by Carlton Fields on

Following the UK’s historic vote to leave the EU, numerous questions have arisen, including whether the UK will really leave the EU and whether Scotland and Northern Ireland (both of which voted to remain in the EU) will have...more

2016-17 New York State Budget

by Hodgson Russ LLP on

On April 13, 2016, Governor Andrew M. Cuomo signed the 2016-17 New York State Budget into law. We summarize the highlights of the revenue provisions below. Personal Income/Estate Taxes Personal Income Tax rates are scheduled...more

Paradox of Mental Incapacity in State Estate Tax: How Moving Your Elderly Parent from Florida May Generate an Unexpected Estate...

by Cole Schotz on

It is a difficult enough for families to come to grips with having to care for an elderly parent that may no longer be able to live on their own. After coming to terms with this unfortunate reality, the next steps often...more

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