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Do ‘economic substance’ tests have any substance?

The European Union, through its Code of Conduct Group on Business Taxation, is drawing up a blacklist of “non-cooperative jurisdictions” that will be subject...
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Offshore substance legislation draws nearer

The European Union last year accused several offshore jurisdictions – the Cayman Islands, Jersey, Guernsey, the Isle of Man, Bermuda and the BVI –...
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Opportunities for crypto-havens to capture business

Blockchain technology is set to drive a new era of global public policy competition. In May 2018, the premier of Bermuda, David Burt, announced...
Deep State

The administrative state

King George III decried Thomas Jefferson in America’s Declaration of Independence “has erected a multitude of new offices, and sent hither swarms of officers...
The Ritz-Carlton, Grand Cayman

Cayman’s economic substance

When talking about the economic substance of an offshore jurisdiction, I believe this is an area where the Cayman Islands particularly excels. Unfortunately, the...
South Africa

South Africa’s dangerous land confiscation game

Trouble may be brewing in South Africa. Although the African National Congress (ANC) backed off its recent land confiscation push, the threat of economic redistributionism...
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More than a bubble

Ten years ago, massive uncertainty roiled financial markets. Major firms collapsed or teetered on the edge of insolvency. Asset values plunged. Every TV show...
The OECD addressed transfer pricing specific issues of intergroup financial transactions, such as treasury functions, intra-group loans and cash pooling.

BEPS – more sticks than carrots and lots of teeth

The Base Erosion Profit Shifting (BEPS) reform has some serious punch. The true extent to which BEPS will reduce aggressive as well as abusive...
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Chapter 11 claims trading: New empirical evidence on how to win plans and influence...

The influence, for good or ill, of hedge funds and other claims traders on the modern Chapter 11 plan process has been the subject...

OECD Watch

Declaring “game over for CRS avoidance,” the OECD announced adoption of model disclosure rules for lawyers, accountants, financial advisors, banks, and other service providers....

The US as the world’s newest IFC and its impact on the Caribbean

During the last decade or so, the status of the U.S. as a superpower has enabled it to increasingly obtain market share from other...
Cryptocurrency coins

Taking on tokenization

You cannot avoid it. Everywhere you turn, people are talking about cryptocurrency, investing in cryptocurrency, debating the future of cryptocurrency. You cannot walk down...