Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
The British Virgin Islands (the BVI), along with most other major offshore jurisdictions, has introduced “economic substance” requirements for entities carrying on certain specified activities. This economic substance regime...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 IRS won a major economic substance case on October 31. A federal district court in Liberty Global, Inc. v. United States, No. 20-cv-03501 (D. Colo.), found that a planned corporate transaction lacked economic substance. ...more