Offshore Companies

News & Analysis as of

David Cameron announces acceleration of new corporate offence of failing to prevent "associated persons" from facilitating tax...

The UK Government has announced the proposed introduction of a new corporate offence of failing to prevent the facilitation of tax evasion. The new offence is likely to build on draft legislation produced in...more

An Analysis of the UK’s New Register of Beneficial Owners

The New Register - From 6 April 2016, most UK companies, LLPs and Societas Europaea became required to maintain a register of “persons with significant control” (PSCs). A PSC is defined as an individual who ultimately...more

“A Look Ahead To 2016” – The Coast Guard Charts Its Course For The Coming Year

The United States Coast Guard Rear Admiral Paul Thomas recently penned an article for the Marine News magazine, February 2016 edition, highlighting the Coast Guard’s “priorities” for 2016. The article is available at the...more

International Tax Advisory: New IRS Notice Continues Attack on Inversions

There is no love lost between the U.S. Treasury and U.S. companies seeking offshore tax homes. Absent congressional action to stem the inversion tide, the Treasury and IRS are left to flex their regulatory and administrative...more

Tax Newsletter - July/August 2015 (China & Hong Kong)

Welcome to the latest issue of our Tax Newsletter. As you may be aware, much has happened since our last issue. In this issue, we highlighted a number of developments in both the PRC and Hong Kong that could be of legal and...more

Significant Amendments Made to Bermuda’s Partnership Legislation

Bermuda is widely perceived as a blue chip offshore financial centre (not just in insurance and mutual funds) and continues to introduce new or amend existing legislation to attract more investors to use the...more

Further Crackdown on Offshore Corporations

In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships. These regulations provide that debt held by foreign...more

CFPB Sues Offshore Payday Lender

On August 4, the CFPB announced the filing of a lawsuit against NDG Eneterprise, a complex web of commonly controlled companies, for collecting money consumers did not owe. The CFPB alleges that the defendants illegally...more

Global Tax News - July 2015

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

More UK Residential Property for the IHT Net

The headline-grabbing inheritance tax (IHT) news from last week’s Budget was the introduction, from April 2017, of an additional nil rate band when a residence is passed on death to direct descendants. However this is only...more

Proposed US Tax Legislation Aims to Curb Hedge Fund Reinsurance

Senator Ron Wyden (D-OR) has released legislation, the Offshore Reinsurance Tax Fairness Act (ORTFA), which aims to close what he perceives to be a loophole used to exploit an exception to the passive foreign investment...more

Goods and Services Tax in Australia to Apply to Offshore Digital Supplies (and More)

Draft Goods and Services Tax (GST) legislation has been released which seeks to level the playing field by ensuring that digital products and services provided to Australian consumers are subject to GST, whether provided by...more

"Restructuring Offshore PRC Debt"

As the growth of the Chinese economy (and the real estate sector in particular) slows, we are seeing stress in an increasing number of issuers of offshore noninvestment-grade People’s Republic of China (PRC) bonds. It seems...more

Deadline for Filing BE-10 Approaches for Private Funds and Private Fund Managers

Most private funds or their managers will be required to file a BE-10 with the US Department of Commerce by May 29th. This year marks the return of the BE-10, the five-year benchmark survey of US direct investment...more

Privy Council Clarifies When Innocent Third Parties are Liable to Victims of Fraud

To what extent must a bank make inquiries as to the commercial purpose of a transaction, particularly a transaction involving an offshore structure? And when is a bank liable to compensate a victim of theft for receiving...more

Corporate Alert: China’s New Tax Regulation on Indirect Disposals Complicates Certain Offshore M&A Deals

In 2009, China’s State Administration of Taxation (SAT) promulgated Circular 698 to empower PRC tax authorities to re-characterize transfers by non-PRC residents of shares in offshore companies that hold equity interests in...more

Banker Settles with SEC for Role in Olympus Scandal

The Securities and Exchange Commission agreed to a settlement with Hajime Sagawa related to his alleged role as the principal and minority owner of a broker-dealer that assisted Japan based Olympus Corporation in its...more

Reducing the risk for Property Professionals of money laundering in UK real estate

Scale of money laundering in UK real estate - Transparency International UK, the anti-corruption organisation, highlighted the risk of money laundering in the high-end UK real estate market in its report published last...more

IRS Hammers Offshore Lending and Underwriting Structure

In a recent Chief Counsel Advice, in an extended analysis the IRS determined that an offshore partnership with a U.S. manager that was engaged in the finance transactions was determined to be engaged in a U.S. trade or...more

What Financial Advisers and Accountants Should Know About Expanded IRS Streamlined Filing Compliance Procedures for U.S. Taxpayers...

The Internal Revenue Service (IRS) recently announced “major changes” to its offshore compliance programs, including the Streamlined Filing Compliance Procedures (Streamlined Procedures), the delinquent international...more

FATCA Violation Underlies Latest US Tax and Securities Fraud Charges

Indictment demonstrates the strength of US law enforcement efforts to combat offshore fraud and is the first to charge a FATCA violation. On September 9, 2014, in US v. Robert Bandfield, et al., federal prosecutors in...more

An Appreciation for Hedging Your Bets on Deferred Compensation

Under Section 457A of the U.S. Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those...more

The Inversion Craze: Will Today's Routine Tax Planning Be Retroactively Outlawed?

Alongside the more typical summer fare, such as coverage of the best beach reading and the latest action movie blockbuster, this summer the media have been abuzz with seemingly daily reports on the latest so-called...more

SEC Efforts To Compel SIPIC Coverage For Stanford Victims Rejected

The D.C. Circuit rejected efforts by the SEC to compel the Securities Investor Protection Corporation to liquidate a broker-dealer that was part of the Stanford Ponzi scheme empire. The investors had purchased CDs from an...more

Export Controls in UK Offshore Centers

Many private equity and investment funds are organized as limited partnerships or companies of offshore entities. Similarly, companies may structure mergers and acquisitions by utilizing offshore holding entities. The British...more

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