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The Corporate Records Nobody Thinks About Until Someone Asks For Them

The Corporate Records Nobody Thinks About Until Someone Asks For Them

Forming a Delaware corporation or limited liability company (“L.L.C.”) is remarkably easy. Remembering what to do with its internal records afterwards can be another matter. Corporate attorneys are frequently asked to form corporations and limited liability companies for use as blockers, holding companies, or acquisition vehicles in connection with a transaction. The entity itself may be only a small part of a much larger transaction, with most of the attention being paid to the purchase agreement, financing documents, or other agreements that is entered into by the newly formed entity. Once the transaction is completed, however, the internal corporate records of the newly formed entity can easily become an afterthought. The issue often resurfaces months or years later when a lender, purchaser, investor, or foreign counsel asks to see them. In his article, Simon Prisk looks at the various ancillary documents that are executed and then frequently ignored by clients that do not have an internal legal department. Examples include (i) certificates of formation, (ii) bylaws, (iii) subscription agreements, (iv) amendments to reflect changes to formal ownership records, and (v) a physical or digital minute book.

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The I.R.S.’s Multifaceted Scrutiny of Partnership Basis-Shifting Transactions

The I.R.S.’s Multifaceted Scrutiny of Partnership Basis-Shifting Transactions

Over the past several years, the I.R.S. has targeted tax-free partnership transactions designed to shift tax basis to property in a way that will yield tax savings for the partner, the partnership, or both. The goal of these transactions is to use the interplay of rules governing inside basis and outside basis to shift tax basis from assets where it is less beneficial for income tax purposes to assets where a higher basis provides greater benefits, i.e., because the asset offers greater cost-recovery deductions or smaller taxable gains when sold. Regulations were adopted in final form during the last days of the Biden Administration, but were withdrawn in Notice 2025-23, with effect as of the date of their issuance. In his article, Wooyoung Lee (i) observes that, while the regulations were withdrawn, the I.R.S. has not withdrawn Rev. Rul. 2024-14, which accompanied the proposed regulations when issued in 2024 and explains the three types of basis-shifting transactions that, in the view of the I.R.S., fail the economic substance doctrine that is codified in Code §7701(o).

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Form 5472 and Foreign-Owned U.S. Entities: The New Chief Counsel Guidance

Form 5472 and Foreign-Owned U.S. Entities: The New Chief Counsel Guidance

Foreign owners of single member U.S. limited liability companies (“L.L.C.’s”) are often told that an L.L.C. with one member is a disregarded entity for U.S. tax purposes. They assume that it means exactly that: disregarded. The assumption is understandable. It was true in almost every relevant respect for many years. It is still true for U.S. income tax purposes. A single-member L.L.C. generally files no income tax return of its own. Its income, deductions, and assets belong to its owner. But the assumption is wrong in one important respect. Since 2017, a foreign-owned single-member L.L.C. has been treated as a domestic corporation for purposes of the reporting and record-maintenance obligations under Code §6038A, involving transactions between the L.L.C. and its foreign related parties. The reporting mechanism is Form 5472 (Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.) The I.R.S. instructions confirm that a reporting corporation includes a ≥25% foreign-owned U.S. corporation, including a foreign-owned U.S. disregarded entity. On April 24, 2026, the I.R.S. released Chief Counsel Advice 202617012 (“C.C.A.”). The C.C.A. addresses when the reasonable cause exception to the Code §6038A penalty applies and, in particular, what it means for the I.R.S. to apply that exception “liberally” for certain small corporations. In her article, Galia Antebi explains (i) Code §6038, (ii) the reasonable cause standard in Treas. Reg. §1.6038A-4(b), and (c) how that standard was applied in the C.C.A. While the C.C.A. may not be used or cited as precedent, it serves to illustrate how the I.R.S. evaluates reasonable cause at the time of the C.C.A.’s issuance.

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Beyond Form W-7: Practical Lessons From the Front Lines of I.T.I.N. Compliance

Beyond Form W-7: Practical Lessons From the Front Lines of I.T.I.N. Compliance

For many non-U.S. individuals, obtaining a U.S. Individual Taxpayer Identification Number ("I.T.I.N.") represents their first substantive interaction with the U.S. tax system. At first glance, the process may appear relatively straightforward: complete Form W-7, provide the required supporting documentation, submit the application to the I.R.S., and await issuance of the I.T.I.N. In practice, however, the process is considerably more nuanced. All of these steps must be coordinated through an I.R.S. Certifying Acceptance Agent ("C.A.A."), assuming the individual does not wish include his or her passport in the packet of documents sent to the I.R.S. In his article, David te Boekhorst, the Founder and the Director of Angularis Global Services Inc., offers practical observations drawn from true life experience working in coordination with legal and tax advisors to assist international clients in navigating the administrative and compliance-related dimensions of the I.T.I.N. application process. He addresses (i) the purpose of the I.T.I.N. program, (ii) the role and responsibilities of the C.A.A., (iii) common misconceptions surrounding I.T.I.N.’s, and (iv) practical lessons learned from guiding foreign individuals through the application process.

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Taxation of Trusts and Foundations in the Netherlands

Taxation of Trusts and Foundations in the Netherlands

Legal systems regarding taxation differ significantly between jurisdictions, and legal vehicles used to attain a specific goal often must be revised when a border is crossed. A clear illustration of this is the discretionary trust, which is a common estate planning tool in the U.S., but is often associated with tax avoidance schemes in the Netherlands. For that reason, assets, liabilities, and income of a discretionary trust are attributed to the contributor under the Afgezonderd Particulier Vermogen (“A.P.V.”) regime. An A.P.V. is defined as a segregated estate that is intended to serve a private interest that is more than incidental. In their article, Stan Stevens, a Partner at HVK Stevens Tax and Legal in Amsterdam, and Sandra Singh, a Director at the same firm, explain the rules and how they are applied in troublesome fact patterns, including unexpectedly harsh treatment if (i) a contributor of a trust moves to the Netherlands, (ii) a nonresident contributor arranges for the trust to have Dutch source income, (iii) a nonresident contributor owns Dutch situs assets at the time of death, or (iv) a Dutch expat individual dies within ten years from the date of expatriation.

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The French 3% Tax on Real Estate: A Guide to Treading in Perilous Waters

The French 3% Tax on Real Estate: A Guide to Treading in Perilous Waters

No rule is more easily ignored than one no one seems to have heard of, and few provisions of French tax law make the point as neatly as the annual 3% tax on the fair market value of French real estate held by legal entities (taxe annuelle sur la valeur vénale des immeubles). Indeed, while having a very broad scope – the 3% tax is never far away where a French real estate property is not owned directly by an individual – it seems to be often overlooked by international investors, exposing them to significant tax risks. The 3% tax was initially conceived as a tracking device to seek out individuals attempting to avoid wealth tax or registration duty. Assessment of the tax is not time-barred until the end of the sixth year following the year involved, leading in the most egregious case to a 21% tax based on the real estate value. In their article, Xenia Lordkipanidze, a Partner in the Tax Department of OVERSHIELD Avocats, Paris, and Clement Pere, a Senior Associate in the Tax Department at the same firm, take a deep dive into the rules, explaining (i) how the tax is computed when a chain of corporations stands between the individual and the property, (ii) the persons who a deemed to be authorized to receive notices from the French Tax Authority, (iii) the 30-day grace period to file late that is offered to first time offenders, (iv) seven applicable exemptions to the 3% tax, (v) adverse case law for persons and entities that challenge the tax, and (vi) several items of practical guidance for affected individuals.

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Belgium Makes Progress on its Long-Awaited Tax Reform

Belgium Makes Progress on its Long-Awaited Tax Reform

With a coalition government in office for 19 months, Belgium is making progress on the implementation of the ambitious tax reform that was announced when the new government was about to be sworn in. Although progress is real, it is taking shape piece by piece instead of one massive overhaul. In their article, Werner Heyvaert, Of Counsel at Advisius Tax & Legal in Brussels, and Yannick Vandenplas, an Associate at the same firm, explain the myriad of changes adopted earlier this year, including (i) the introduction of a broad capital gains tax on financial assets for Belgian individual taxpayers, followed up in administrative guidance that was issued in July, (ii) stricter rules for the dividends received deduction for Belgian corporations and for the dividend withholding tax exemption allowed to nonresident corporations, (iii) changes to the company exit tax regime, allowing for taxation of the “Liquidation Bonus” realized by individual shareholders, (iv) the adoption of a special tax regime for “carried interests,” (v) an overhaul of the tax regime for newly arrived expats, (vi) a revision to the Investment Deduction regime, a tax incentive allowing Belgian businesses to deduct a notional portion of the purchase price or investment cost of qualifying fixed assets made during the year, and (vii) the adoption of mandatory digital invoicing.

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Insights Vol. 13 No. 3: Updates & Other Tidbits

Insights Vol. 13 No. 3: Updates & Other Tidbits

This month, Nina Krauthamer and Wooyoung Lee look briefly at two recent developments in tax. The first addresses pied-à-terre homes in New York City. Following tax policies adopted by certain cities in Canada, a yearly property tax surcharge will be imposed on New York City homes worth $5 million or more when (i) the home is not used as a primary residence for the owner or for a family member or (ii) is not rented out on full-time basis to an individual who uses the unit as a primary residence. The second development is reported by an anonymous source in contact with an unnamed immigration lawyer. According to the source, the I.R.S. is considering a change to Form 1040 (U.S. Individual Income Tax Return) to add two check boxes to the form. One will be used to indicate (a) whether the resident filer is or is not a U.S. citizen. The second will be used to identify w

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I.R.S. Offers New Settlement For Easement Tax Shelters

I.R.S. Offers New Settlement For Easement Tax Shelters

In May, the I.R.S. announced a settlement offer for partnerships involved in disputes concerning “syndicated conservation easements.” The dispute involves the value of charitable deductions claimed in regard to the grant of an easement that prevents the owner from developing land. An easement is a legal right that allows one party to use a specific portion of someone else’s property for a specific, limited purpose without actually owning the land. The grant purportedly becomes a tax shelter when (i) multiple unrelated investors (ii) pool their money in a partnership or syndicate (iii) that is formed to acquire various parcels of undeveloped land (iv) for the principal purpose of contributing development rights to a land trust, (v) that allows the investors to claim charitable contribution deductions at purportedly inflated values far in excess of the investment in the land. In their article, Stanley C. Ruchelman and Wooyoung Lee explain the history of this typically U.S. centric tax shelter to readers outside the U.S.

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Q.S.B.S. Stacking: Is the Clock Ticking?

Q.S.B.S. Stacking: Is the Clock Ticking?

“Q.S.B.S.” is a tax related acronym in the U.S. for Qualified Small Business Stock. When a start-up corporation meets certain conditions enumerated in Code §1202, noncorporate investors are offered the opportunity to derive tax-free capital gains by holding the investment for a period of time prior to a liquidity event. The greater of $10 million of gain or 10 times the taxpayer’s basis in the Q.S.B.S. – referred to as “basis loading – may be exempt from tax on exit. The tax benefit can be enhanced by creating multiple irrevocable nongrantor trusts, each formed for the benefit of a specific family member. Each trust is entitled to its own capital gain exemption, so long as the multiple trust rule of Code §643(f) is not triggered. Under that rule, multiple trusts having (i) the same grantor, (ii) substantially the same primary beneficiaries, and (iii) an income tax avoidance purpose are treated as a single trust.. Among savvy investors, the tax plan is known as “stacking.” In her article, Galia Antebi reports that Treasury Assistant Secretary for Tax Policy Kenneth Kies recently signaled that Treasury does not like stacking. The bad news is that forthcoming Q.S.B.S. guidance is expected to limit taxpayers’ ability to multiply the benefit. The good news is that basis loading is not a target – at least for now.

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Cross-Border Wealth Planning – Five Questions to Answer When Planning a Move to Italy

Cross-Border Wealth Planning – Five Questions to Answer When Planning a Move to Italy

When individuals consider moving their tax residence to Italy, the first conversation almost always begins with a specific question. How will I be taxed in Italy? It is a question that comes most naturally to clients who have read about Italy’s special regimes. But is it the only question that should be considered? In her article, Giada Mazzola, Senior Counsel at Caldara & Associati in Milan, cautions that an adviser who treats the first conversation as a tax-rate conversation will produce an answer that may be technically correct, but may be problematic for practical reasons related to the way the client chooses to live. A more useful approach is one that asks the five questions that all begin with the letter “W” – Who? What? When? Where? and Why? An adviser will be able to fashion a tax plan and a life plan that meets the needs of the client over the long haul only when those five questions are asked by the adviser and answered by the client (i) fully, (ii) completely, and (iii) honestly.

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Beneficial Ownership Reporting Update in B.V.I. – From Filing Obligations to Enforcement Risks

Beneficial Ownership Reporting Update in B.V.I. – From Filing Obligations to Enforcement Risks

In the past year, the British Virgin Islands (“B.V.I.”) beneficial ownership information (“B.O.I.”) reporting regime moved from consultation and transition to implementation and enforcement in ways that may affect more than companies and their beneficial owners. Areas of the law that are potentially affected, include (i) beneficial and legal ownership and title, (ii) proprietary rights, (iii) shareholder disputes, (iv) creditor rights and secured lending, (v) fiduciary obligations, (vi) registered agent duties, (vii) privacy, (viii) cross-border confidentiality, and (ix) potential public law challenges to administrative decision-making.that may affect more than companies and their beneficial owners. In his article, Joshua Mangeot, a leading advisor on the implementation of the B.V.I. economic substance and beneficial ownership reporting requirements, points out that these are areas of the law that areprovides an update on the B.V.I. position, focusing on points most likely to matter to international tax advisors, family offices, corporate and fiduciary service providers, trustees, private banks, fund managers, litigators, and end-clients using B.V.I. companies or limited partnerships in cross-border structures. It raises potential issues regarding (i) beneficial and legal ownership and title, (ii) proprietary rights, (iii) shareholder disputes, (iv) creditor rights and secured lending, (v) fiduciary obligations, (vi) registered agent duties, (vii) privacy, (viii) cross-border confidentiality, and (ix) potential public law challenges to administrative decision-making. Clearly, the adoption of the B.O.I. reporting regime can be viewed to be the equivalent of the proverbial camel’s nose under the tent.

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The Final Chapter: Testamentary Instruments for Global Families

The Final Chapter: Testamentary Instruments for Global Families

As more families live, invest, and hold assets across multiple countries, estate planning increasingly requires coordination between legal systems that are not designed to work together. A foreign Will, alone, may not effectively administer U.S. assets, while a U.S. Will drafted in isolation can unintentionally disrupt an existing foreign estate plan. An important objective in cross-border estate planning is the creation of complementary structures that minimize probate friction, provide efficient tax planning for beneficiaries, and preserve the client’s intended dispositive scheme across jurisdictions. In her article, Allison Dolzani (i) explores several key cross-border testamentary planning considerations for global families with U.S. beneficiaries and U.S. assets and (ii) suggests planning, practical, and logistical guidance for U.S. estate administration of a foreign estate.

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Tiger Global Case Denies Treaty Benefits Claimed by Mauritius Companies

Tiger Global Case Denies Treaty Benefits Claimed by Mauritius Companies

The Supreme Court of India issued a landmark ruling in the case of three Mauritius entities owned by the Tiger Global Group in the U.S. The three entities were private companies incorporated in Mauritius. They were formed to undertake investment activities aimed at long-term capital appreciation and investment income. They were regulated by the Mauritius Financial Services Commission (“F.S.C.”) and held Category I Global Business Licenses under the Financial Services Act, 2007. Each held a valid Tax Resident Certificate issued by the Mauritius Revenue Authority, which certified their status as tax residents of Mauritius for income tax purposes. The Indian Supreme Court was unimpressed. The arrangement had the correct form, but in the facts presented, the form lacked economic substance. Abbas Jaorawala, a Senior Director and Head-Direct Tax of Khaitan Legal Associates, Mumbai, explains all.

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Portuguese Dividends Paid to European C.I.V.'s – Local Law vs. E.U. Fundamental Freedoms

Portuguese Dividends Paid to European C.I.V.'s – Local Law vs. E.U. Fundamental Freedoms

The taxation of dividends paid by Portuguese resident companies to nonresident C.I.V.’s has become one of the most litigated and structurally significant issues in Portuguese tax law. What began as a technical discussion concerning the scope of a domestic tax exemption has evolved into a consolidated body of caselaw confirming a structural incompatibility between Portuguese tax legislation and European Union law, in particular the principle of free movement of capital. In his article, António Gaspar Schwalbach of Spear Legal, Lisbon, revisits the Portuguese tax regime applicable to dividends distributed to C.I.V.’s, and addresses the practical consequences for nonresident funds, asset managers, and custodians, including the recovery of withholding tax and indemnity interest.

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French Budget 2026 – Overview of Significant Provisions

French Budget 2026 – Overview of Significant Provisions

The French Finance Act for 2026 introduced several measures affecting private wealth structuring and investment strategies. Some provisions were expected and were discussed in previous legislative debates. Others target specific structuring techniques traditionally used for wealth preservation or intergenerational planning. Philippe Stebler, of Stebler Moati Avocats, Paris, explains the tax provisions that were adopted, including (i) the extension of minimum income taxation of 20% for individuals, (ii) adjustments to the tax deferral regime applicable to share-for-share exchanges occurring before cash-outs through holding companies, (iii) the imposition of a new 20% tax is imposed on certain luxury assets held through holding companies, (iv) the exclusion of luxury assets held by companies from the “Dutreil” regime, a major tax relief mechanism for business transfers by gift or inheritance, and (v) an extension of the temporary surtax for large corporations.

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Decoding Complexities of India Budget 2026-27

Decoding Complexities of India Budget 2026-27

Nirmala Sitharaman, the Indian Finance Minister, presented Budget 2026-27 on February 1, 2026. It promises significant tax benefits for nonresident investors operating in specific sectors of the economy. Jairaj Purandare, the Chairman of JMP Advisors Pvt. Ltd., Mumbai, Bhakti Shah, a Director of JMP Advisors Pvt. Ltd. in Mumbai, and Siddhita Desai, a Senior Associate at JMP Advisors Pvt. Ltd., Mumbai, take a deep dive into the budget. Highlights include (i) expansion of the preferential time periods for I.F.S.C. and O.B.U. tax benefits, (ii) an exemption for income of a foreign company that arises in India from procuring services from a specified data center in India, (iii) an exemption for income of foreign companies arising from the provision of capital goods, equipment, or tooling to a contract manufacturer in India, (iv) an exemption for overseas income of a nonresident individual for five consecutive tax years where the nonresident visits India for the first time to render services under an approved program, (v) the adoption of a unified 15.5% safe harbor in the Indian transfer pricing rules for providing information technology services with a cap of U.S.$2.2 billion, and (vi) expansion of the benefit of an A.P.A. to cover affiliates of the taxpayer that applied for the A.P.A.

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The Relevance of Relevance and the Economic Substance Doctrine

The Relevance of Relevance and the Economic Substance Doctrine

The economic substance doctrine has a long-standing history in U.S. tax law, stretching back over 90 years. Case law also developed other related doctrines, such as the business purpose doctrine and step-transaction doctrine, all of which attempted to answer the same question – was the business transaction real or was it a charade intended solely to reduce tax. Code §7701(o), entitled “Clarification of economic substance doctrine,” was enacted in 2010 to codify the preexisting regime. The legislative history provided an angel list of transactions that were not viewed abusive. For those transactions and others that did not contain hallmarks of tax avoidance, it was accepted that the economic substance doctrine was not relevant. Indeed, the statute provides that, with limited exception, if the economic substance doctrine was not relevant to a fact pattern prior to the enactment of Code §7701(o), the economic substance doctrine would not be relevant after the enactment of that provision. Then, in 2023, the I.R.S. put on its sheriff’s hat and turned the angel list into a hit list, taking the position that Code §7701(o) was a game changer. In their article, Stanley C. Ruchelman and Wooyoung Lee examine two recent cases, Liberty Global and Patel, in which the I.R.S. position was that case law was no longer relevant if planning became too aggressive. The I.R.S. won both cases, but the jury is out as to the validity of its position.

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Luxembourg’s New Carried Interest Tax Regime

Luxembourg’s New Carried Interest Tax Regime

Carried interest tax regimes are under review across several countries in which major fund hubs are based. Policy trends diverge, with some jurisdictions tightening tax privileges in response to fairness and anti-avoidance debates, while others recalibrate to attract or retain fund talent and decision making substance within an investment fund context. Seeking to foster and strengthen its position as a major investment fund hub, the Luxembourg government proposed legislation to reform the existing carried interest regime. In his article, Adnand Sulejmani, a senior associate in the Luxembourg tax practice of Ashurst, explains that the existing law fostered inconsistent interpretations among practitioners regarding the taxation of carried interests and contained a sunset provision for the benefit. In comparison, the proposed legislation emphasizes tax certainty for participating investment management professionals and a permanent favorable tax regime. The proposed legislation is expected to be enacted before the end of January 2026, with an effective date as of January 1, 2026.

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Colombia: A Primer For Those Doing Business With or In The Local Market

Colombia: A Primer For Those Doing Business With or In The Local Market

Colombia is a beautiful country, known for its unique biodiversity, natural landscapes, and cultural richness. It is the fourth largest economy in Latin America, and frequently serves as a regional operations platform for South America, Central America, and the Caribbean. However, tax rules in the country can be problematic. Foreign entrepreneurs providing consulting, technical, management, or administration services to local residents or businesses are subject to withholding tax at rates between 20% and 33%. Foreign providers of streaming services, online ads, data management, and digital goods may be subject to a gross tax based on sales that is triggered by reason of having a significant economic presence in the country. Other foreign companies may trip into worldwide tax exposure if Colombia is viewed to be the effective place of management of the company. The threshold for this risk is low as the risk potentially exists from short-term presence in Colombia by executives or employees. Finally, the standard under which an individual is viewed to be tax resident is not straightforward. In his article, Eric Thompson, a partner of attorneys Cañón Thompson, Bogota, identifies the various areas of risk and cautions that companies trading with Colombia or individuals who move to Colombia require careful advance planning.

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