Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
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 Department for International Tax Co-operation (DITC) issued a revised version (version 3.2) of the Guidance on Economic Substance For Geographically Mobile Activities in July 2022 (Revised ES Guidance Notes)....more
The States of Jersey’s Comptroller of Revenue is withdrawing the temporary concession that it issued in March 2020 in relation to the application of Economic Substance and Corporate Tax Residency Requirements during periods...more
The Bermuda Registrar of Companies (RoC) has advised that it will be launching the first phase of its new company registry system on 7 June 2021. Economic Substance Declarations that have been started must be finished and...more
Relevant entities carrying on all types of relevant activity (except for those carrying on intellectual property business) under the International Tax Co-operation (Economic Substance) Act (2021 Revision) (“ES Act”) with a...more
Economic substance regulations have been circulating in various forms across several jurisdictions during the last couple of years. They are being introduced across the globe in countries with low or no corporate taxation in...more
UK General Tax Developments - HMRC updates guidance on what constitutes "ordinary share capital" - Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this...more
Traditionally, in the world of international tax planning, it has not been uncommon to see corporate structures utilizing entities organized in offshore jurisdictions that do not impose an income tax on corporate earnings –...more
The Tax Court’s recent opinion in Austin v. Commissioner, TC Memo 2017-69, claims to be following the Fourth Circuit’s view of the economic substance doctrine by calling it the sham transaction doctrine, saying it is an issue...more
Earlier this month, Massachusetts Mutual Life Insurance Company (MassMutual), represented by Skadden, won a federal appeal permitting the company to deduct policyholder dividends in the year the dividends were declared, even...more