Category: Uncategorized

Subsequent modifications to Indian tax residency rules

In view of the outbreak of COVID-19 pandemic, the Finance Minister of India presented several statutory and regulatory relief measures last week.  One of the...

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Equity markets are pricing in a worse than average US recession. The VIX is at 80. Have we seen the worst?

Look at history – present volatility suggests peak panic will create a bottom in stock prices. VIX peaked in October 2008. S&P500 price bottom in...

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The Ground is Moving – Focus on What You Can Control!

  There are 4 stages to the psychological impact of epidemics. As entrepreneurs we need to push the dialogue from panic and fear to rational...

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Woodpoint Letter (Q1 2020): Correction or recession?

Market volatility reminds investors to understand risk In our last investment letter, we examined the macro environment moving into 2020 and discussed key factors that...

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International Estate Planning: Intestacy in a cross-border context – How would your Estate be distributed?

“Intestacy’ refers to the circumstances when a person dies without a valid Will. In a cross-border context, this could occur where: 1. a person dies...

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Restructuring your US operations – Part 3: Anti-avoidance rules in the Internal Revenue Code

Where a corporate reorganization results in a transfer of property to a foreign corporation (such as an Australian registered company), the normal nonrecognition rules in...

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CGT and foreign resident beneficiaries: TD 2019/D6 and TD 2019/D7

The Australian Taxation Office recently released draft Taxation Determinations TD 2019/D6 and TD 2019/D7. The combined effect of the draft Determinations is that capital gains...

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The U.S. GILTI rules do not correspond to Australia’s CFC attribution rules for the purposes of the Australian hybrid mismatch rules: TD 2019/D12

The ATO has just released draft Tax Determination TD 2019/D12 in which it confirms that section 951A of the U.S. Internal Revenue Code (IRC) is...

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The U.S. Tax System: The TCJA’s attempt to move from Worldwide to Territorial

I wanted to take the chance to break down some of the big picture topics mentioned in the article, The Expansion of “United States” Taxpayers:...

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Trump Tax Reform Puts Domestic Business First and Foreign Founders Last

Written by: Peter Harper and Janpriya Rooprai Illustrations by: Janpriya Rooprai Peter heads CST Tax Advisors in North America and a member of the global...

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