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Forthcoming Event

International Taxation: Residence vs Source

The two basic concepts of international taxation are residence and source. Where these exist in different jurisdictions, there is the potential for double taxation which is precluded either through unilateral legislation or double tax treaty arrangements. At the same time, we need to consider the anti-avoidance legislation that exists universally to deny tax benefits which were not intended...

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Addressing the Tax Challenges of the Digital Economy

Dear Sirs. We write in response to the request for comments on the Public Discussion Draft on BEPS Action 1: Address The Tax Challenges Of The Digital Economy 24 March 2014. We are pleased to offer our comments as follows. In respect of the specific issues on which you have requested comments. Whether it is possible to ring-fence the digital economy from the rest of the economy, and if not...

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AIFMD and LLP Tax reform - There are now two ways about it

The Finance Bill 2014 is scheduled to be enacted next month. Perhaps one of its more anticipated consequences is its final address to the dilemma of deferred remuneration under the AIFMD. Though the public is not short of guidance papers from HMRC on the topic, we present a summary of the issue and its hopeful resolution. Casting back to last year, the implementation of the Alternative...

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UK Annual Tax on Enveloped Dwellings - ATED

The ATED is an annual UK tax charge, targeted at expensive UK residential property held by a non-natural person (‘‘NNP’’)1  where the property is not rented out to an unconnected third party but instead it is left unoccupied or is used by the ultimate beneficial owner (or persons connected to the beneficial owners) of the NNP. Reliefs (such as property development or property rental) can apply...

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Senate Report on Offshore Tax Evasion Released

On February 26, 2014, the United States Senate Permanent Subcommittee on Investigations released a report regarding offshore tax evasion and specifically the actions of Credit Suisse, Switzerland’s second largest bank. The report is the product of a two-year investigation initiated in 2011 after seven Credit Suisse bankers were indicted by the U.S. Department of Justice (DOJ)...

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U.S. Government Cracking Down on Tax Evasion Through Swiss Insurance

On February 24, 2014, The Wall Street Journal reported that the IRS is investigating Swiss Private Placement Life Insurance (PPLI) companies in order to determine whether American citizens have been using PPLI to hide assets or otherwise evade taxes in the United States. PPLI combines private banking and portfolio management into a life insurance structure. This development is not...

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Closing Tax Gaps - OECD launches Action Plan on Base Erosion and Profit Shifting

OECD's Action Plan on Base Erosion and Profit Shifting (BEPS) offers a global roadmap that will allow governments to collect the tax revenue they need to serve their citizens. It also gives businesses the certainty they need to invest and grow. Produced at the request of the G20 and introduced at the G20 Finance Ministers' meeting in Moscow, the Action Plan identifies 15 specific...

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About Us

Shorex is a specialist media group for the wealth management industry and the high-end luxury market. Our purpose is to provide our partners, delegates and visitors with an effective networking platform where they can forge productive relationships and come away with strong ideas... read more

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