News & Analysis as of

Trusts International Tax Issues

Cadwalader, Wickersham & Taft LLP

A Toothless Tax Avoidance Scheme: M Northwood v HMRC

The UK’s First-tier Tribunal (“FTT”) has denied a taxpayer a deduction for contributions to a remuneration trust on the basis that such payments did not give rise to an expense under generally accepted accounting principles...more

Hogan Lovells

How the UK Trust Registration Service applies to trusts of real estate and changes for unit trusts

Hogan Lovells on

Trustees which are UK resident, have UK assets or income which trigger a UK tax liability or directly acquire UK land on or after 6 October 2020 will generally have to register the trust with HMRC's Trust Registration Service...more

Cadwalader, Wickersham & Taft LLP

Haworth: Residency Tie-Breaker Tests in a ‘Round the World’ Tax Scheme

The UK’s First-tier Tribunal recently considered the application of the “place of effective management” residency tie-breaker test found in double tax treaties in the recent case of Haworth and others v HMRC [2022] UKFTT 34...more

McDermott Will & Emery

[Webinar] International Tax Transparency Update - November 18th, 3:00 pm GMT

McDermott Will & Emery on

Our International Tax Transparency Update will cover DAC6, the UK’s Trust Registration Service and other global registration requirements that may be relevant for businesses. The importance of these requirements cannot be...more

Womble Bond Dickinson

Impact Investing: A Growing Trend For Foundations On Both Sides Of The Pond

Womble Bond Dickinson on

The last few years have seen an increasing number of foundations engage in a wide spectrum of impact investing i.e. investing to generate a social return and further their mission or a social purpose, rather than investing to...more

Schwabe, Williamson & Wyatt PC

Summary of Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Goodwin

IRS Amends Revenue Ruling 81-100 to Permit Participation in Group Trusts by Puerto Rico Plans and Insurance Company Separate...

Goodwin on

The Internal Revenue Service (the “IRS”) issued Revenue Ruling 2014-24 (the “Ruling”). The Ruling amends Revenue Ruling 81-100, the ruling that established the requirements applicable to a tax-qualified group trust. The...more

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