Pearse Trust Blog



EU Publishes Ireland's Post-Bailout Health Check

Posted by Pearse Trust on Thursday, 19-Apr-2018 16:00:00

Ireland’s latest post-bailout review from the European Union suggests that the economy’s remarkable recovery from the financial crisis continues. However, there could be some bumps in the road ahead, and these are largely related to external economic and tax developments.

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Tags: Ireland, Tax, Economy

UK Simplifies Tax Rules For Termination Payments

Posted by Pearse Trust on Tuesday, 17-Apr-2018 11:00:00

UK employers currently contemplating or negotiating employee termination agreements as well as employees anticipating receipt of termination payments should be aware of changes to the relevant tax regime which will apply for the 2018-19 tax year onwards.

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Tags: Tax, UK

UK Tax Deductibility Of Corporate Interest

Posted by Pearse Trust on Thursday, 12-Apr-2018 16:00:00

In the 2016 Autumn Statement, the Chancellor of the Exchequer announced a consultation in respect of a new corporate interest restriction regime following the recommendations made by the OECD on preventing base erosion profit shifting.

The resulting new rules are included in Finance Act (No. 2) 2017, taking effect retrospectively from 1 April 2017 irrespective of a company’s financial year-end.

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Tags: Tax, UK

The Canadian Limited Partnership [An Overview]

Posted by Pearse Trust on Tuesday, 10-Apr-2018 11:00:00

The Canadian Limited Partnership (‘LP’) is increasingly used as a vehicle for the conduct of international transactions and the holding of investments.

Notwithstanding the fact that the Canadian LP does not have separate legal status (unlike for example the Scottish LP), the LP is an attractive holding arrangement for foreign investors with portfolios or other investments outside Canada.

Irrespective of the absence of legal personality, where a Canadian LP holds US portfolio investments, it may elect corporate tax treatment under US tax law while still maintaining its transparent taxation status under Canadian law.

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Tags: Legal, Tax, Canada, Limited Partnerships

S-Corp vs C-Corp: US Business Owners Ponder Tax Reform

Posted by Pearse Trust on Wednesday, 04-Apr-2018 13:45:00

Tax reform was intended to reduce and simplify taxation for small businesses in the United States, especially those organised as “pass-through” entities, known as S corporations. However, the huge cut in corporate tax from 35% to 21% has given small business owners even more food for thought as they plan their tax affairs for 2018. Read More

Tags: Tax, USA

Guidance Issued on Northern Ireland's New Corporate Tax

Posted by Pearse Trust on Monday, 02-Apr-2018 13:45:00

The UK tax authority, HM Revenue and Customs (HMRC), has issued draft guidance on how Northern Ireland’s separate corporate rate will be administered.

Background

As a constituent nation of the United Kingdom, Northern Ireland is generally subject to UK law. Therefore, companies are subject to the UK's 19% corporate tax rate (for 2017/18).

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Tags: Ireland, United Kingdom, Tax

UK Royalty Tax Proposal – Room For Improvement?

Posted by Pearse Trust on Wednesday, 28-Mar-2018 13:45:00

The United Kingdom Government recently concluded a public consultation on a new measure intended to tackle tax base erosion and profit shifting (BEPS) and ensure that companies operating in the digital economy are taxed “appropriately.”

The measure in question is intended to extend the UK withholding tax regime to certain outbound royalty payments connected with the exploitation of IP rights in the UK. However, while other jurisdictions have since proposed similar types of measures, tax practitioners in the UK have cast doubt over how the tax can be applied.

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Tags: United Kingdom, Tax, VAT

Follow the MAP — Resolving Double Taxation Disputes

Posted by Pearse Trust on Monday, 26-Mar-2018 13:45:00

The jury is still out on whether the OECD’s base erosion and profit shifting project is improving the international tax framework, or making it even more uncertain. However, if the OECD is correct then one aspect of the BEPS plan is having a positive effect on international business and commerce by reducing the time and resources taxpayers spend to resolve double taxation disputes, with this improvement largely attributable to a process known as the Mutual Agreement Procedure, or MAP.

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Tags: Tax, EU

Trust Protector – A Role For The Professionals?

Posted by Pearse Trust on Wednesday, 21-Mar-2018 13:45:00

Although not compulsory, the appointment of an appropriate Trust Protector is becoming increasingly relevant as the application of trusts for estate planning and asset protection evolves.

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Tags: Legal, Trusts

UK Reviews Inheritance Tax

Posted by Pearse Trust on Monday, 19-Mar-2018 13:45:00

The UK's Office of Tax Simplification (OTS) has been tasked with investigating options for reform of the UK's inheritance tax.

While unlikely to be a root-and-branch review of this much-maligned and often complex tax, tax experts do suggest that the sort of changes to be explored could be a step in the right direction.

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Tags: United Kingdom, Tax