Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
It has now been over a year since the updated Enforcement Guidelines: Economic Substance (the “Guidelines”) were issued on 31 March 2023, outlining the enforcement powers and processes of the Cayman Islands Tax Information...more
The Economic Substance Act 2018 (the “Act”)1 requires Bermuda-based entities that are carrying on a “relevant activity” in a relevant financial period and entities claiming “non-resident entity” status under the Act to file...more
Liberty Global Inc. ("LGI") and the Department of Justice are in fierce litigation over the application of the economic substance and step transaction doctrines to a transaction for which LGI claimed a dividends received...more
Welcome to the latest edition of our Quarterly Corporate Update covering recent developments in the British Virgin Islands. Following the flurry of legislative amendments in the latter half of 2022 and Q1 2023, Q2 has...more
BVI legal entities are required to make an annual economic substance filing. A large number of BVI entities carry on passive holding business. As a result of recent changes to the Economic Substance Guidance Notes, the...more
The Economic Substance Act 2018 (the “Act”) requires Bermuda-based entities that are carrying on a “relevant activity” in a relevant financial period and entities claiming “non-resident entity” status under the Act to file an...more
Welcome to the latest edition of our Quarterly Corporate Update covering recent developments in the British Virgin Islands. The first quarter of 2023 saw a raft of amendments to existing BVI legislation being introduced...more
The Bermuda Registrar of Companies (the “Registrar”) issued an industry notice on 17 August 2022 confirming that changes required to address certain system errors within the Registrar’s Online Register Portal (the “Portal”)...more
The Economic Substance Act 2018 (the “Act”) requires Bermuda-based entities that are carrying on a “relevant activity” in a relevant financial period and entities claiming “non-resident entity” status under the Act to file...more
Following the introduction of the Economic Substance (Companies and Limited Partnerships) Act 2018 ( ES Act) and the passing of the deadline for the first filings thereunder to be made by BVI entities, the BVI International...more
The Economic Substance Amendment Act 2021 was enacted on 30 June 2021, bringing within scope of the Economic Substance Act 2018 all Bermuda partnerships and overseas partnerships that are engaged in a relevant activity,...more
With effect from 30 June 2021 the International Tax Co-operation (Economic Substance) (Amendment) of Schedule Regulations, 2021 serve to expand the application of the International Tax Cooperation (Economic Substance) Act...more