United States: Court Rules That Payment In Excess Of Fair Market Value Of Stock Is Compensation

The Tax Court has ruled in Brinkley v. Commissioner (T.C. Memo 2014-227) that a payment an employee received in excess of the fair market value of the stock he held was compensation instead of capital gain.

The case centered on the compensation of Brian Brinkley, a founder and chief technology officer of Zave Networks, Inc., which began business in 2006. In exchange for his services, he received restricted stock grants from the company, and he […]

By |November 25th, 2014|

South Africa: Dividend Payments To Holland – Did You Spot The Aperture?

By now it is accepted that the payment of dividends to non-South African shareholders are subject to dividends tax which is levied at a rate of 15%, unless such rate is reduced by an applicable double tax agreement (DTA). To this end, most DTAs are drafted in such a manner that the rate of dividends tax is reduced to 10% or 5%, depending on the percentage of shares the beneficial owner holds in the […]

By |November 25th, 2014|

Cayman Islands: Cayman Finance Seminar To Look At International Tax Initiatives

Anyone interested in finding out more about some of the multilateral initiatives proposed and confirmed with regard to international tax — such as FATCA, multilateral automatic exchange of information, and central registries of beneficial ownership, among others — should attend this special seminar hosted by Cayman Finance. Scheduled to take place on Thursday 23rd January 2014 at the Westin Grand Cayman Resort, this one-day event will cover such initiatives with particular focus as to […]

By |November 24th, 2014|