Recent bills in the U.S. House of Representatives and Senate demonstrate legislators’ concerns about several issues related to nonprofits, including: (1) admissions practices at institutions of higher education; (2) cross-border grantmaking by U.S ...
On 31 January 2024, the UK government will bring into force HM Treasury’s proposed reforms to the financial promotion rules. The Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (FPO) contains restrictions on the issue of communications which amount to “promotions” of investments in securities ...
Last year, the UK Government announced increases in fees for immigration and nationality applications as well as priority processing services which took effect from 4 October 2023. As mentioned in our previous article, these increases are substantial and likely to have a significant financial impact for applicants and their sponsors. In addition, the UK Government are increasing the Immigration Health Surcharge shortly on 6 February 2024 ...
The last installment of our three-part series explains U.S. tax considerations of a divided interest strategy for the bare owner who is a U.S. person. In most situations involving global families, it is the bare owner, rather than the holder of the usufruct, who is a U.S. person. The usufruct holder is often a nonresident alien who puts in place the property division for foreign estate planning purposes. In many instances, one or more members of the younger generation move to the United States ...
The Supreme Court of Texas has issued its much-anticipated opinion on an open attorney’s fees question in the area of First Party Property appraisals. The issue came to the Texas Supreme Court on a certified question from the 5th Circuit and considers the practical effect of the Texas Legislature’s 2017 amendments to the Texas Prompt Payment of Claims Act, Chapter 542, Insurance Code ...
The use of cryptocurrency or crypto assets in employee incentive arrangements is a relatively new and evolving area and it is therefore important to carefully consider the potential advantages and disadvantages of their use in incentive arrangements. Different types of crypto assets Crypto assets can take many forms including digital currency such as Bitcoin and Litecoin and NFTs (non-fungible tokens) such as art NFTs and collectible real estate NFTs ...
Pension funds: hedging longevity risk Bulk Annuities Market Recent hikes in interest rates have led to huge increases in the funding levels of many UK defined benefit pension schemes (DB Schemes). Now they are in surplus, many DB Schemes are considering a bulk annuity transaction or "buy-in". As a result, the bulk annuity market is booming ...
Recently, the General Directorate of Customs (DGA), under the provisions of art 440 of the Regulation of the Uniform Central American Customs Code (RECAUCA), has modified the period of stay for vehicles owned by foreign tourists, Salvadorans residing abroad, and Salvadoran students residing abroad ...
On 23 June 2023, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Circular (RMC) No. 71-2023 and Revenue Memorandum Order (RMO) No. 23-2023 to provide streamlined guidelines and the prescribed documentary requirements for the processing of value added tax (VAT) refund applications. The following significant amendments were introduced to the existing regulations outlined in this article ...
The new double tax treaty between Belgium and the Netherlands will introduce significant changes compared to the current Article 5 on permanent establishments. Due to the positions of Belgium and the Netherlands to the Multilateral Instrument (MLI), only the anti-fragmentation rule is applied under the current treaty. Under the new treaty, alignment is sought and found with the other changes proposed by the MLI for permanent establishments ...
From Dominic Cummings to Nicola Sturgeon, 2023 was a noisy, headline-grabbing year for the UK’s public inquiry into the Covid-19 pandemic. What’s coming in 2024? And what does it mean for businesses? In terms of media exposure, the first full year in the life of the UK’s official Covid-19 Inquiry was a resounding success ...
SyCipLaw’s Tax Department has listed down its Top 10 Tax Issues and Practical Solutions (T.I.P.S.) for 2023. Please read the full text hereor via this link. The SyCipLaw's Top 10 Tax Issues and Practical Solutions (T.I.P.S ...
in the past week, guidance has been provided by both the Ministry of Finance and the Federal Tax Authority (FTA) regarding deadlines for Corporate Tax registration.The new deadlines have the potential to significantly reduce the time left for meeting the deadlines for Corporate Tax registration. For example, certain applicable taxable persons will be required to submit the Corporate Tax registration applications by 31 May 2024 in order to avoid a violation and the applicable penalties ...
In an earlier article in this series, we already discussed the planned changes in terms of moveable income. Whilst the changes may seem relatively limited at first glance, Dutch residents immigrating to Belgium will however encounter several peculiarities as set out in this article. Capital gains Capital gains, i.e. on shares, are in principle taxable in the state of residence ...
On February 12, 2024, the Court of Appeal of Quebec handed down its decision in Société d?assurance Beneva inc. c. Bordeleau,1 dealing in particular with the burden of proof incumbent on an insurer when it denies coverage on the basis of an insured?s intentional fault, and an award of damages against an insurer for breach of its duty of good faith. The facts This decision was rendered further to a dispute between Société d?assurance Beneva inc ...
Many founders are familiar with tax-exempt charitable organizations. These nonprofit entities—which are commonly known by reference to Section 501(c)(3) of the Internal Revenue Code—are operated exclusively for a broad range of charitable purposes. 501(c)(3) organizations come in a wide range of flavors, including private foundations, donor-advised funds, and public charities ...
Maximising benefits: The importance of efficiently leveraging W&I Insurance to structure M&A deals Warranty and Indemnity (“W&I”) insurance is a risk management tool that transfers the liability of the seller to the insurer. W&I insurance typically covers the breach of warranties and indemnities provided by a seller/warrantor and the occurrence of events that were unknown or undisclosed to a buyer ...
SyCip Salazar Hernandez & Gatmaitan (SyCipLaw) senior partner Carina "Caren" Laforteza and special counsel Catherina "Kate" Fernandez discuss the taxation of AI in light of recent developments concerning the concept of situs of taxation as interpreted by the Bureau of Internal Revenue (BIR), the local tax authority in the Philippines ...
Although it is not often well-understood in business and tax circles, the Indian Act (the ?Act?), coupled with federal and provincial tax laws, provides several tax planning opportunities for Indigenous taxpayers. These laws provide various tax exemptions for people who qualify as ?Indians? under the Act, as well as for ?bands? and other ?councils ...
Shoosmiths’ mobility partner, Ben Gardner, was a speaker at SMMT Connected 2024, hosted in London. Ben moderated a panel discussion focused on the remaining challenges to a safe and responsible commercial rollout of automated vehicles. The summit was aimed at addressing the latest advancements in connected and automated vehicle technology. The UK’s automotive sector leads the charge in this transformative revolution, making substantial investments in cutting-edge technologies ...
On January 1, 2024, regulations implementing the Corporate Transparency Act (“CTA”) became effective, triggering new reporting obligations for many entities conducting business within the United States ...
