REDiscovering The Business Trust   Discovering The Business Trust  New Entrepreneurs and experienced Investors are all now faced with what was once a simple question?  “How do I organize the ownership and administration of my enterprise?” Today, the world’s market and its players are all conscious to an unprecedented degree. Our respective Governments understand and…

Modern Tax Planning and ‘Ramsay.’  THE FUTURE OF OUR CAPITAL GAINS In the world of international tax law, it is as though the judgement of WT Ramsay Ltd v IRC [1982] AC 300, (1981) 54 TC 101 was a remedy for all. Parliament, Tax Commissioners the ‘Average Man” and Individuals all walked away feeling like they won, something. However,…

The Importance of The Qualified Business Asset Investment (QBAI) To the Reduction of GILTI. As US Taxation of CFCs becomes more complex, US business owners want to accumulate more capital and grow their businesses faster, in order to deal with mounting uncertainty and the local impact of global markets. US Persons who own or are…

  Global Intangible Low Tax Income (GILTI) Tested Income of US Persons For many years, the US Subpart F rules caused controversy and confusion. The taxation of foreign corporations owned by US persons was a complex landscape to traverse even by the most skilled and experienced. Taxation of Effectively Connected Income further added to the…