SyCipLaw's Tax Department has prepared an international edition of its Tax Issues and Practical Solutions (T.I.P.S.) for the third quarter of 2023. Please read the full texthereor via thislink. The SyCipLaw T.I.P.S - International Edition covers the following tax issues: 1 ...
What is a JPUT? A Jersey Property Unit Trust (JPUT) is a legal structure whereby legal ownership of assets (primarily non-Jersey real estate) is vested in one or more trustees who hold the assets on trust for the benefit of unitholders upon the terms of a written trust instrument. What are the benefits of a JPUT? JPUTs have many plus points: Familiarity: JPUTs are generally recognised and accepted by investors, lenders, advisers, regulators and tax authorities in the UK and elsewhere ...
Probate and estate administration for non-Jersey domiciliaries Why do I need a Jersey grant of representation? Jersey is an independent legal jurisdiction for estate administration purposes ...
Law firms periodically receive requests for advice from CPAs regarding a client’s need to come into compliance with the relatively new and sometimes confusing “economic nexus” or “Wayfair” rules for selling goods or providing services to customers in another state ...
Most founders are familiar with Section 1202 of the Internal Revenue Code, which provides a tax exemption for the sale of Qualified Small Business Stock (QSBS). Less well known is Section 1202's cousin, Section 1045, which provides certain tax benefits for a "rollover" of proceeds from the sale of QSBS into replacement QSBS. The basic rules are as follows: The original QSBS must be owned for at least 6 months prior to its sale ...
The recent Autumn Statement contained little support for charities as the sector continues to face increased demand, higher costs and reduced funding ...
Since the enactment of the statutory donor-advised fund (“DAF”) rules under the Pension Protection Act of 2006, sponsoring organizations that manage DAF programs have relied on the Internal Revenue Code (“IRC” or the “Code”) and certain limited administrative guidance to structure and operate DAFs ...
Please note the following press release. This press release is available at our homepage. Heuking advises the City of Frankfurt am Main on leasing LATERAL Towers A team led by Heuking Partner Dr. Frank Baßler advised the City of Frankfurt am Main on legal and tax matters associated with leasing the “Lateral Towers” from CELLS group ...
On November 2, 2023, in response to certain controversy, the Canada Revenue Agency (?CRA?) sought to clarify the application of the new disclosure rules, in force since June 22, 2023. The CRA?s comments relate, in particular, to the impact of reporting obligations on severance agreements, a topic we initially covered a few weeks ago1. We believe it is appropriate to go over these clarifications ...
One solution to this issue is for pension funds to transfer longevity risk to the reinsurance market. Such a transfer can be attractive for both parties. From the pension fund’s perspective, a life reinsurer is often an attractive counterparty, both because of its deep understanding of the nature of the risk being transferred, and because it can provide a balance sheet big enough to assume a meaningful amount of risk from the fund ...
Carey Olsen in Bermuda advises Hamilton Insurance Group on its Initial Public Offering on the New York Stock Exchange Bermuda-headquartered Hamilton Insurance underwrites specialty insurance and reinsurance risks on a global basis through its wholly owned subsidiaries. Enhanced by data and technology, the firm is focused on producing sustainable underwriting profitability to deliver shareholder value ...
Corporate status A foundation company is a body corporate with a legal personality distinct from its members, directors and other connected persons. As foundation companies are governed by the Companies Act (Revised), except where it is inconsistent with the Foundation Company Act (2017), they benefit from an extensive body of case law and are well recognised in other jurisdictions ...
SyCipLaw's Tax Department has prepared Tax Issues and Practical Solutions (T.I.P.S.) for August. The August 2023 issue covers the following tax issues: 1. May the ruling in the 2011 case of Commissioner of Internal Revenue v ...
Mexico has just announced significant tax incentives for companies in certain key industries to relocate operations to Mexico. A government decree issued on October 11, 2023 seeks to boost the nearshoring trend targeting ten export-oriented manufacturing sectors. Nearshoring is the process by which a company relocates operations offshore, but close to the market where it intends to sell its products ...
The Finnish government proposes significant changes to transfer taxation. Transfer tax is levied on the acquisition of shares and other securities and real property. The proposed changes may have significant effects to the taxation of M&A and real estate transactions. Some of the proposed changes will decrease the tax burden while some will result in increased tax liability. The most significant changes include: The general rate for securities (1 ...
After a particularly active consultation round with approx. 140 consultation responses, together with the proposal for the national budget for 2024, the government presented a revised proposal today, 6 October 2023. The criticism from a relatively united renewables industry must be said to have fallen on relatively deaf ears and the proposal is essentially a continuation of the consultation proposal ...
With the recent implementation of electronic invoicing in El Salvador, it is of interest for taxpayers issuing VAT control documents to know the platforms enabled by the Tax Administration to comply with the technical and regulatory requirements established to allow the digitalization of the invoicing process. Art. 119-A of the Tax Codestates that electronic tax documents (DTE) shall be governed by the provisions of said code ...
On September 28th, Law 21,614 of the Ministry of Labor and Social Security was published in the Official Gazette (hereinafter the “Law”), which establishes amendments to Law No.21,063, which Creates an Insurance for the Accompaniment of Children Suffering from Diseases as Indicated and Modifies the Labor Code for these purposes (hereinafter “SANNA Law”) ...
