Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
In 2024, there has been a sharp increase in the number of enforcement actions initiated by the Cayman Islands Tax Information Authority (“TIA”) and fines levied against relevant entities (such as Cayman Islands exempted...more
A warm welcome to the Summer edition of Conyers Coverage. The whirlwind that is the Cayman Islands (re)insurance industry continues to blow with gusto! To keep you updated on recent developments, we include various items from...more
It has now been over a year since the updated Enforcement Guidelines: Economic Substance (the “Guidelines”) were issued on 31 March 2023, outlining the enforcement powers and processes of the Cayman Islands Tax Information...more
The International Tax Co-operation (Economic Substance) Act (2024 Revision) (the “ES Act”) was brought into force to demonstrate the commitment of the Cayman Islands as a member of the Organization for Economic Co-operation...more
Approaches and developments - The Cayman Islands has long been a leading offshore jurisdiction for investment funds, as well as a significant global financial centre overall. It is therefore not surprising that, reflecting...more
Limited Liability Companies (“LLC”) are a familiar structuring tool for US managers and investors, and the introduction of the Jersey LLC is part of a strategy by the jurisdiction to increase its appeal to the US market. ...more
The Department for International Tax Co-operation (DITC) issued a revised version (version 3.2) of the Guidance on Economic Substance For Geographically Mobile Activities in July 2022 (Revised ES Guidance Notes)....more
A very warm welcome to our eighth edition of Conyers Coverage. As we start to wind down on 2022 #TeamConyers is already reflecting on what a hectic and exciting year it’s been for the Cayman Islands (re)insurance industry –...more
The Economic Substance Amendment Act 2021 was enacted on 30 June 2021, bringing within scope of the Economic Substance Act 2018 all Bermuda partnerships and overseas partnerships that are engaged in a relevant activity,...more
With effect from 30 June 2021 the International Tax Co-operation (Economic Substance) (Amendment) of Schedule Regulations, 2021 serve to expand the application of the International Tax Cooperation (Economic Substance) Act...more
Relevant entities carrying on all types of relevant activity (except for those carrying on intellectual property business) under the International Tax Co-operation (Economic Substance) Act (2021 Revision) (“ES Act”) with a...more
The deadline set by the Cayman Islands Department for International Tax Cooperation (“DITC”) for filings by relevant entities that carry on intellectual property business (“IP Companies”) and entities claiming tax residency...more
The European Council has announced its decision to remove the Cayman Islands from the EU list of non-cooperative jurisdictions for tax purposes. In February we reported on Cayman’s inclusion on the list and our expectation...more
On 18 February 2020, the ECOFIN committee of finance ministers of the EU resolved to add the Cayman Islands to the EU blacklist of non-cooperative jurisdictions for tax purposes. Their reasoning was short...more
Traditionally, in the world of international tax planning, it has not been uncommon to see corporate structures utilizing entities organized in offshore jurisdictions that do not impose an income tax on corporate earnings –...more