United States: Proposed Regulations On Excepted Health Benefits Released

The IRS, the Department of Labor and the Department of Health and Human Services recently issued proposed regulations(REG-132751-14) that would amend existing regulations regarding excepted benefits. These benefits are generally exempt from requirements under the Health Insurance Portability and Accountability Act and the Affordable Care Act.

The proposed rules would allow group health plan sponsors, in limited circumstances, to offer wraparound coverage to employees purchasing individual health insurance in the private market, including through the […]

By |January 21st, 2015|

Making Australian employee share option plans possible

1 Introduction
The Government has published exposure draft legislation to lessen the taxation of Australian employee share and share option plans. If implemented, tax changes introduced in 2009, that effectively put a stop to the use of employee share option plans in Australia, will be reversed, and wider tax concessions for share and option plans will also be introduced.

This draft legislation follows an announcement made in October of last year (see our previous update in […]

By |January 20th, 2015|

Malta: The Importance Of Substance In International Tax Planning

Substance is a key theme in international structures and in international tax planning.  Various tax authorities and Courts around the world are attacking structures which lack substance.

A considerable number of international tax planning structures such as finance companies, holding and sub-holding companies, intellectual property structures and trading companies are still being established to benefit from tax laws of other foreign jurisdictions in order to benefit from favourable conditions of double taxation agreements.

This can, for […]

By |January 20th, 2015|