Cayman Islands: Cayman Joins Other Nations In Signing Multilateral Agreement

The Cayman Islands today took a significant step against global tax evasion in joining more than 50 countries and jurisdictions in signing an agreement that sets the worldwide standard for automatic exchange of information (AEOI) among tax authorities.

The Multilateral Competent Authority Agreement (MCAA) was developed by the OECD, in cooperation with G20 countries. Minister of Financial Services, Commerce and Environment, Wayne Panton, signed the Cayman Islands’ formal Declaration on Joining the MCAA.

‘Although Cayman is […]

By |October 30th, 2014|

United States: IRS Reaches Conclusion On Bank Transaction With Federal Financial Assistance

In an internal legal memorandum (ILM 201441014) released Oct. 20, the IRS concluded that a corporation couldn’t take a carryover basis in certain assets acquired in a transaction in which Section 597 applies.

Under the facts of the memorandum, the state’s banking department closed a chartered bank (Failed Bank), and named an “agency” (as defined in Treas. Reg. Sec. 1.597-1(b)) as the receiver. Failed Bank owned a single-member limited liability company (Bank LLC) that was […]

By |October 30th, 2014|

United States: IRS Issues Guidance Under Codified Economic Substance Doctrine

The IRS on Oct. 9 issued a notice providing additional guidance on the codification of the economic substance doctrine and related penalty amendments.

Notice 2014-58 amplifies Notice 2010-62, and provides guidance on the definition of “transaction” in applying the economic substance doctrine under Section 7701(o) and on the meaning of “similar rule of law” under the Section 6662(b)(6) accuracy-related penalty. It is effective for transactions entered into after March 30, 2010.

Congress codified the doctrine in […]

By |October 29th, 2014|