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Ogier | Guernsey | 30 Jul 2021

Economic substance extended to certain partnerships

In a further amendment to the economic substance regulations, the Income Tax (Substance Requirements) Implementation Regulations 2021 recently came into force. The main amendment to the economic substance regime is that the regulations will apply to certain newly formed Guernsey partnerships as of 1 July 2021 and many other Guernsey partnerships that existed on 30 June 2021 from 1 January......
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Ogier | Guernsey | 29 Jul 2021

Economic substance extended to certain partnerships

In a further amendment to the economic substance regulations, the Income Tax (Substance Requirements) Implementation Regulations 2021 recently came in to force. The main amendment to the economic substance regime is that the regulations will apply to certain newly formed Guernsey partnerships as of 1 July 2021 and many other Guernsey partnerships that existed on 30 June 2021 from 1 January......
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Allen & Overy LLP | Slovakia | 11 Apr 2019

Has Slovakia become an arbitration-friendly jurisdiction?

In 2018 the Slovak courts addressed a number of issues while upholding arbitral awards, suggesting that the jurisdiction is becoming more arbitration friendly. This article explores two of these issues – namely, whether courts should review the application of substantive law and facts established by tribunals and the use of public policy as grounds for setting aside an award.
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Forsters LLP | United Kingdom | 4 Apr 2019

Court U-turn in approach to 'out of time' inheritance act claims

Shortly after rejecting a claim under the Inheritance (Provision for Family and Dependants) Act outside the statutory six-month time limit, the High Court of Justice allowed a claim to be brought 25 years and nine months after the deadline. As the statutory deadline had passed, the court exercised its discretion in favour of the claimant based on, among other things, the merits of her claim......
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Forsters LLP | United Kingdom | 7 Mar 2019

Tips for discussing a nuptial agreement

The prospect of discussing a nuptial agreement may seem daunting, but if approached in the right way it can form part of an important conversation about a couple's future together. If a couple can agree the central elements of a nuptial agreement before lawyers draw up the document, this will help to minimise potential areas of disagreement and can pave the way for a constructive negotiation....
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BDO LLP | India | 8 Feb 2019

Mumbai Tax Tribunal's recent rulings

The Mumbai Tax Tribunal recently considered whether the conversion of a company into a limited liability partnership could be considered a transfer even though it had failed to meet all of the conditions set out in Section 47(xiiib) of the Income Tax Act. In another case, the tribunal referred to a Delhi High Court ruling and stated that preference shares are part of a company's share capital......
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Thorsteinssons LLP | Canada | 16 Mar 2018

Subjecting transfers of beneficial ownership to property transfer tax is not as simple as it might seem

The British Columbia Property Transfer Tax Act applies only to registered transfers of real property. However, significant real property-related tax changes are rumoured to be proposed in the upcoming provincial budget. Any amendment to the act that would tax transfers of beneficial ownership should not be made haphazardly. Such an amendment must be joined by, among other things, a mechanism......
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Thorsteinssons LLP | Canada | 9 Mar 2018

Taxation of bitcoin and other cryptocurrencies

At a basic level, cryptocurrencies constitute property under the Income Tax Act. As such, dispositions of cryptocurrencies ordinarily lead to income tax consequences. Although cryptocurrencies are an exciting development, along with the rewards come a variety of risks, not least of which is tax. Failure to comply with all applicable tax obligations can result in severe penalties and hefty......
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Morrison & Foerster LLP | USA | 27 Feb 2018

SEC budget highlights capital formation and small business capital formation

In the recently released Congressional Budget Justification, the Securities and Exchange Commission (SEC) highlighted a number of priorities. The request notes that the Division of Corporation Finance remains focused on measures designed to promote capital formation. It also references the SEC's intent to "propose amendments to further facilitate capital formation through exempt and......
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Thorsteinssons LLP | Canada | 23 Feb 2018

Federal Court of Appeal confirms 'half-loaf' plan is subject to GAAR

The latest chapter in the story of the 'half-loaf' plan was recently penned by the Federal Court of Appeal. The case concerned a plan by which the taxpayer intended to split the capital gains on a share sale to an arm's-length purchaser between him and his wife and thus benefit from both of their lifetime capital gains exemptions. On appeal, the taxpayer argued that none of the conditions of......
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