By choice or regulation, the future of the maritime industry bends toward decarbonization. The industry contributes (by one estimate) almost 3% of global greenhouse gas emissions and depends on one of the dirtiest energy sources, bunker fuel. But cleaner alternatives are on the horizon for everyone. Companies that commit to decarbonization early have an opportunity to drive change instead of reacting to it ...
On January 5, 2023 the SEC announced a settled Administrative Proceeding with Randy Robertson. Mr. Robertson previously served as the co-portfolio manager for the BlackRock Multi-Sector Income Trust (“BIT”). While serving as the co-portfolio manager for BIT, Mr. Robertson explored the possibility of a BlackRock investment opportunity regarding a potential secured lending investment relating to print and advertising expenses associated with film distribution. Mr ...
Matters of cross-border company mobility are addressed at European Union level by means of Directive (EU) 2017/1132 (the “2017 Directive”) which provides for cross-border mergers and domestic divisions of public limited liability companies ...
Many government agencies set goals for their construction projects to be awarded to disadvantaged business enterprises (DBE). The U.S. Department of Transportation (DOT) DBE certification program sets antidiscrimination regulations that states can implement for federal funding. The Certification Office for Business Inclusion and Diversity (COBID) is the certifying authority of DBEs (on behalf of the DOT) in Oregon ...
The U.S. Department of Justice’s Office of Legal Counsel recently released an advisory opinion[i] regarding Section 1461 of title 18 of the U.S. Code. In it, they write the “Comstock Act”[ii] does not prohibit the mailing of certain medications used to perform abortions where the sender does not believe the medications will be used unlawfully. This opinion comes in the wake of the U.S ...
Following the enactment of Sub-Decree No. 196 (“Sub-Decree 196”) on the 28th of September 2022 by the Royal Government of Cambodia (click here ) the Ministry of Economy and Finance (MEF) issued Instruction 017 on the 27th of December 2022 on the Implementation of the new rates of Tax on Salary ...
With the well-known challenges of the last ten months or so, market conditions deteriorated substantially over 2022 and the venture capital (VC) market became a far more challenging one in which to agree a valuation and raise money. While those challenges are not over, from speaking to VC clients and others, there's a cautious optimism that as 2023 progresses the market will slowly improve ...
On January 11, 2023 the SEC Division of Investment Management issued an additional Marketing Rule FAQ. The newly issued FAQ addresses gross and net performance requirements applicable to private fund case studies, single investments and/or groups of investments, i.e. extracted performance. Specifically, the Question provides as follows: Q. When an adviser displays the gross performance of one investment (e.g ...
This year marks the fifth anniversary of the introduction of the transfer pricing regime in Cambodia. Recent changes in local transfer pricing regulations, tax audit practices, and documentation mean that now – more than ever – you need the right advisor to reduce the tax audit risks associated with related party transactions. DFDL Cambodia’s specialized transfer pricing team combines international experience and deep knowledge of the local legal and tax environment ...
Broad scope of application The FSR targets any undertaking engaged in an economic activity in the internal market that has received a foreign subsidy distorting the internal market. A foreign subsidy is any financial contribution provided by a third country (non-EU Member State) which confers a benefit on an undertaking engaging in an economic activity in the internal market and which is limited to one or more undertakings or industries ...
The automotive industry is undergoing a rapid transformation, and the changes over the next 12 months are likely to be significant. As the industry moves towards a more sustainable and “green” future, the way we use and interact with cars is likely to change dramatically alongside. This is partly driven by the continued rise of electric vehicles (EV), with EV’s securing a 15.1 per cent share of the UK's new car market as of December 2022 ...
In recent months we have seen a significant rise in industrial action across multiple sectors, including public transport; postal workers; nursing and ambulance staff; university employees; Border Force staff and civil servants. Strikes look set to continue into 2023; the British Medical Association is currently balloting junior doctors on potential strike action for March 2023 and disruption is also likely to hit schools in Scotland as teacher strikes are planned for January 2023 ...
Most commentators agree that the equity capital markets are not in robust health as we enter 2023. Investors have sustained significant losses in recent months and the combination of war, inflation and recession mean that investor confidence is at a definite low. There are however some signs that the outlook for 2023 may not be as bleak as the headlines might suggest ...
The rules on exit tax on shares and certain other securities mean that private individuals who move from Norway and becomes resident for tax purposes in another country must pay tax for latent profits on shares etc., as if the shares had been sold the day before emigration. Change in law is now in force As the rules have been until 28 November 2022, the exit tax ceased to apply if the shares were not realized five years after emigration ...
We summarize here what we believe are the top 5 Alabama tax cases decided in the past year that would interest our CPA readers. Not surprisingly, almost all are Alabama Tax Tribunal rulings, so in those instances we deleted that reference and simply list the date of the latest ruling. If you’d like a copy of or have a question about any of these rulings, please email one of us ...
The Finnish Government has published a proposal for the temporary Windfall Tax Act in Finland, the draft of which was briefly discussed in our previous article on the subject. The proposed temporary windfall tax would be applicable to so-called windfall profits gained during tax year 2023 by companies operating in the electricity or the fossil fuel sector. The aim of the proposal is to tax said sectors' increased profits resulting from the current energy crisis ...
On December 9, 2022, the Office of Chief Counsel of the Internal Revenue Service (“IRS”) issued a General Legal Advice Memorandum (“Memorandum”) challenging the 1994 Tax Court decision inChilds v. Commissioner, 103 T.C. 634 (1994),aff’d without published opinion, 89 F.3d 856 (11thCir. 1996) (“Childs”) ...
On December 30, 2022, the Asset Management Association of China ("AMAC") issued a consultation draft of the Measures for Registration and Filing of Private Investment Funds (《私募投资基金登记备案办法 (征求意见稿)》) (the "Draft Measures") and the ancillary Guidelines No. 1-3 on private fund manager registration〔i.e. Guideline on Basic Operational Requirements ("Guideline No. 1"), Guideline on Shareholders, Partners and Actual Controllers ("Guideline No ...
On 14 December 2022, following a campaign by the Royal Yachting Association, the UK Government confirmed that it would not be implementing changes to HMRC policy to enable UK residents that purchased (EU) VAT paid UK vessels located in the EU prior to the end of the Brexit transition period (31 December 2020) to bring these vessels back into the UK without incurring a second (UK) VAT charge ...
A lesser-known state incentive in the nonprofit sector has created a boon for taxpayers, private education institutions and their students. Across the country, states are providing tax credits that reduce individuals’ state income taxes for any donation to a state-certified nonprofit organization providing scholarships to K-12 students to attend private schools ...
Kudun and Partners has successfully represented Thanulux Public Company Limited (“TNL”), the biggest market leader in the manufacturing and sale of ready-made clothes and leather goods in Thailand, on the listed company’s major restructuring and expansion of its investment with a highly significant total value of THB 8.8 billion ...
The task of upgrading and developing the UK’s electric vehicle (EV) charging infrastructure to cope with current and future demand is no mean feat. The UK Government has committed to ending the sale of new petrol and diesel cars by 2030 ...
Where is my order? I’m sure most of us have asked this question many times and probably more so recently as the recent postal strikes have left customers waiting for delayed Christmas gifts to arrive. The postal strikes have undoubtedly had a huge impact on businesses in the lead up to Christmas, especially given the dramatic increase in online sales, costing businesses money and time in navigating through customer queries, complaints and providing solutions ...
In this briefing, we will review the implications of the Law for property transactions in Jersey. Tax on purchase of residential properties which are not used as a main residence The key implication of the Law is that stamp duty (and equivalent land taxes such as land transactions tax and enveloped property transactions tax) on acquisitions of domestic residential property which will not be the purchaser's main residence will be increased ...
Recently approved Cabinet Decision 85 of 2022 (the Decision) outlines the requirements and conditions for classification of persons as a “Tax Resident” of the UAE. We briefly outline below who qualifies as a UAE tax resident. Afridi & Angell have assisted a variety of clients in procuring tax domicile certificates and are well versed in the procedures and requirements ...
