The British Virgin Islands (the BVI), along with most other major offshore jurisdictions, has introduced “economic substance” requirements for entities carrying on certain specified activities. This economic substance regime...more
The UAE has established comprehensive regulations to determine tax residency for individuals and businesses operating within its borders. Three key legislative instruments guide these determinations: Cabinet Decision No....more
Double taxation arises when the same income is taxed in two different jurisdictions, potentially leading to excessive tax burdens for individuals and businesses. The UAE has developed a comprehensive legal framework to...more
Special Economic Zone Companies offer a straightforward and cost effective way of establishing a physical presence in the Cayman Islands, enabling eligible businesses and their employees to access the benefits of living and...more
For the first time since the enactment of the False Claims Amendment Act of 2020, the DC Attorney General’s (AG’s) Office has used its new tax enforcement powers to pursue an alleged personal income tax deficiency. This...more
Boasting an enviable lifestyle, modern infrastructure and a highly sophisticated financial services industry and all within a short flight of Miami and other US cities, the Cayman Islands check all the boxes for individuals...more
Overview - If you have read any of my articles in the past, you should know by now that I am a major fan of Afro-Cuban music, aka Salsa. You also know by now that I grew up in the Panama Canal Zone. One of my friends at...more
A new double taxation treaty between France and Luxembourg was signed on 20 March 2018 (the “New Treaty”). This New Treaty will replace the current tax treaty dated 1 April 1958, as amended several times and for the last time...more
On November 19, 2015, Treasury issued Notice 2015-79 (the “Notice”), which announces Treasury’s intent to issue regulations reducing the tax benefits available to inverted groups and making it more difficult for some U.S....more
The Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF), has recently issued FAQs regarding the immobilisation of bearer shares and units, as well as a press release to remind...more
HMRC has released a series of consultations regarding financial services taxation. The proposed measures are in line with the Government’s “UK investment management strategy”, a commitment announced in the 2013 Budget to...more