Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Bermuda is the world’s leading domicile for captive insurance companies, with over 600 active captive licences on its register generating over US$24 billion in gross written premium. Having formed the first modern captive in...more
In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more
The International Tax Co-operation (Economic Substance) Act (2024 Revision) (the “ES Act”) was brought into force to demonstrate the commitment of the Cayman Islands as a member of the Organization for Economic Co-operation...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
The deadline set by the Cayman Islands Department for International Tax Cooperation (“DITC”) for filings by relevant entities that carry on intellectual property business (“IP Companies”) and entities claiming tax residency...more
The European Council has announced its decision to remove the Cayman Islands from the EU list of non-cooperative jurisdictions for tax purposes. In February we reported on Cayman’s inclusion on the list and our expectation...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
On 18 February 2020, the ECOFIN committee of finance ministers of the EU resolved to add the Cayman Islands to the EU blacklist of non-cooperative jurisdictions for tax purposes. Their reasoning was short...more
Cabinet resolution number 31 of 2019 concerning economic substance requirements was recently published on the Ministry of Finance website. The issuance of this resolution requires companies operating a ‘relevant activity’ 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
In order to address concerns raised by the EU Code of Conduct Group, a number of jurisdictions have recently taken steps to meet the European Union’s tax good governance principles by introducing “substance” rules for...more