Comments for International Tax http://www.worldcommercereview.com/blog/international_tax Welcome to the World Commerce Review tax blog. This is a joint venture with Merlyn International Tax Services, one of Europe’s leading tax boutiques. The blog will examine the current and pending tax issues which effect companies trading in Europe. We will comment and lobby on behalf of our readers, addressing their concerns and putting forward initiatives and ideas. This blog is here to serve our readership - please forward your comments and questions . Tue, 23 Aug 2011 15:55:11 +0000 http://wordpress.org/?v=2.9.2 hourly 1 Comment on “Check the box” on China and The Netherlands even if you are not a US taxpayer! (The use of hybrid entities in international tax planning structures part V) by Aaron Lenz http://www.worldcommercereview.com/blog/international_tax/?p=30&cpage=1#comment-26 Aaron Lenz Tue, 23 Aug 2011 15:55:11 +0000 http://www.worldcommercereview.com/blog/international_tax/?p=30#comment-26 Forgot to mention, the examples I give concern the States, but I'm interested in the generic rules about the interaction between the fund sponsor's domicile, the fund manager's domicile, the limited partners' nationalities, the jurisdiction of the fund's target investment, and any other pertinent factors I've overlooked. Cheers, AL Forgot to mention, the examples I give concern the States, but I’m interested in the generic rules about the interaction between the fund sponsor’s domicile, the fund manager’s domicile, the limited partners’ nationalities, the jurisdiction of the fund’s target investment, and any other pertinent factors I’ve overlooked.

Cheers,
AL

]]> Comment on “Check the box” on China and The Netherlands even if you are not a US taxpayer! (The use of hybrid entities in international tax planning structures part V) by Aaron Lenz http://www.worldcommercereview.com/blog/international_tax/?p=30&cpage=1#comment-25 Aaron Lenz Tue, 23 Aug 2011 15:44:58 +0000 http://www.worldcommercereview.com/blog/international_tax/?p=30#comment-25 Try your legal finesse on this if you care to: I'm an American student at a top college and plan on a career in fund management. Before such a time as I run my own funds and my compensation comes mainly in the form of carried interest, I intend to expatriate and set myself up advantageously (i.e. passport in Dominica, fund sponsor in Cayman Islands, domicile in Bahamas). I know, for example, that foreign investors in U.S. securities pay zero U.S. capital gains on those securities and if there is also no tax liability based on citizenship and/or residence, I would expect to pay no taxes at all. There are yet some ambiguities in my mind, however, surrounding the treatment of the general partner in different scenarios. For my U.S. feeder funds, in which LPs would be paying full U.S. capital gains, would my share still be tax-exempt in the same way as it would be for my Cayman feeders? On the flip-side, would I still have to pay foreign specific taxes such as FIRPTA on U.S. real estate investments even for my U.S. feeders? Try your legal finesse on this if you care to:

I’m an American student at a top college and plan on a career in fund management. Before such a time as I run my own funds and my compensation comes mainly in the form of carried interest, I intend to expatriate and set myself up advantageously (i.e. passport in Dominica, fund sponsor in Cayman Islands, domicile in Bahamas). I know, for example, that foreign investors in U.S. securities pay zero U.S. capital gains on those securities and if there is also no tax liability based on citizenship and/or residence, I would expect to pay no taxes at all. There are yet some ambiguities in my mind, however, surrounding the treatment of the general partner in different scenarios. For my U.S. feeder funds, in which LPs would be paying full U.S. capital gains, would my share still be tax-exempt in the same way as it would be for my Cayman feeders? On the flip-side, would I still have to pay foreign specific taxes such as FIRPTA on U.S. real estate investments even for my U.S. feeders?

]]> Comment on “Check the box” on China and The Netherlands even if you are not a US taxpayer! (The use of hybrid entities in international tax planning structures part V) by Saulfair Holm http://www.worldcommercereview.com/blog/international_tax/?p=30&cpage=1#comment-12 Saulfair Holm Wed, 27 Jul 2011 07:45:36 +0000 http://www.worldcommercereview.com/blog/international_tax/?p=30#comment-12 Great aricle ... Great aricle …

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