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Structuring considerations for hedge funds
  • Ogier
  • Cayman Islands, Global
  • September 1 2011

Most open ended funds in Asia are structured using a Cayman Islands company as the fund vehicle.

Sale of assets for fair market value between a marital trust and a nonmarital trust to settle a dispute between beneficiaries and trustees of the trusts was neither a taxable gift nor a transfer of an income interest in a QTIP Priv. Ltr. Rul. 201119003
  • Proskauer Rose LLP
  • USA
  • July 5 2011

In this private letter ruling, the issue was whether the transfer of assets for fair market value between a marital trust and a nonmarital trust resulted in a taxable gift or a disposition of an income interest in qualified terminable interest property (“QTIP”).

Consultation on UK tax domicile and residence
  • CMS Cameron McKenna Nabarro Olswang LLP
  • United Kingdom
  • June 20 2011

Following on from the changes announced in the Budget on 23 March 2011 (the “Budget”), the Government has launched its consultation on the reforms to the UK taxation of non-domiciled individuals (“non-doms”) and a statutory definition of tax residence and ordinary residence.

Budget 2011
  • Mills & Reeve LLP
  • United Kingdom
  • May 4 2011

There were a number of announcements in the Budget that may have an impact on your personal tax planning in the near future.

EBTs: inheritance tax and income tax
  • Squire Patton Boggs
  • United Kingdom
  • May 3 2011

HMRC have issued a new brief (1811) setting out their view of the inheritance tax and income tax implications of contributions to an EBT by a close company.

Procedures available for the voluntary dissolution of a Guernsey company
  • AO HALL Advocates
  • Guernsey
  • April 8 2011

Under the Companies (Guernsey) Law, 2008 (as amended) (the "Law") there are two procedures available for the voluntary dissolution of a Guernsey company.

The rise of restricted purpose companies
  • Harneys
  • British Virgin Islands
  • March 22 2011

When British Virgin Islands (BVI) company law was amended and restated on 1 January 2005, one of the new features which largely went unnoticed was the introduction of a new type of company - the restricted purpose company.

Migration of companies to and from Guernsey
  • AO HALL Advocates
  • Guernsey
  • January 7 2011

From a legal perspective, a reference to the 'migration' of a company is a reference to the process of the transfer of the company's registration to another jurisdiction, whilst maintaining the legal personality of that company.

2010 revisions to New York power of attorney statute take effect September 12
  • Katten Muchin Rosenman LLP
  • USA
  • August 24 2010

New York has further amended its power of attorney statute to address some of the issues caused by the sweeping changes made to the statute, which went into effect on September 1, 2009.

U.K. "round the world" scheme grounded
  • Stikeman Elliott LLP
  • Mauritius, United Kingdom, Jersey
  • August 10 2010

It was a bright and calm day when Mr. Smallwood, a U.K. resident, decided to suggest that a Jersey Trust of which he was the settlor, and in which he maintained an interest, should dispose of certain shares.