Economic Substance Doctrine: Complying With U.S., European Union, Cayman Islands, Nevis, and BVI Guidelines
Recording of a 110-minute CPE webinar with Q&A
This webinar will review the economic substance doctrine from the perspective of the U.S., EU, and offshore jurisdictions. Our panel of global tax attorneys will explain how to comply with the U.S. economic substance rules, European directives, and similar requirements of other offshore locations, including the British Virgin Islands, Cayman Islands and Nevis.
Outline
- Economic substance: introduction
- U.S. rules on economic substance
- Evolution and codification
- Case law
- European directives
- Danish cases
- Noncooperative jurisdictions
- Anti-Tax Avoidance Directive (ATAD)
- DAC 6
- The Unshell Directive
- Offshore economic substance
- Cayman Islands
- Nevis
- British Virgin Islands
Benefits
The panel will cover these and other critical issues:
- Pertinent U.S. case law relative to the economic substance doctrine
- The two prong compliance test for economic substance
- European directives including The Unshell Directive and ATAD
- Complying with economic substance guidelines in the Cayman Islands and BVI
- Best practices to meet economic substance guidelines in the U.S. and abroad
Faculty
Werner Heyvaert
Partner, Tax
AKD
Mr. Heyvaert is a partner at AKD and has 35 years of experience in Belgian and international tax law and specialises in... | Read More
Mr. Heyvaert is a partner at AKD and has 35 years of experience in Belgian and international tax law and specialises in advisory and litigation work in the field of direct taxes for businesses, such as institutional and transactional corporate tax, taxation of various forms of employee compensation and European and international tax law.
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David Payne
Global Head of Governance
Bolder Group
Mr. Payne has been working in the corporate, fiduciary, legal, trust, financial and alternative financial services... | Read More
Mr. Payne has been working in the corporate, fiduciary, legal, trust, financial and alternative financial services industry since 2004, specializing in alternative investment vehicles and asset managers. As Global Head of Governance, one of his main tasks is to implement and supervise client facing economic substance solutions and procedures in the different jurisdictions in which Bolder operates amongst other regulatory requirements/services. Mr. Payne’s prior roles/responsibilities include group legal counsel and top executive positions for different Bolder offices in Europe, the Caribbean, and US, including acting as Managing Director for the BVI, Cayman, Nevis and US offices supervising all Corporate, Trust, Fiduciary, Captive Insurance, Compliance and Fund matters. He is also the Managing Partner of BGA Law, a law firm with offices in the British Virgin Islands, Cayman Islands and Hong Kong.
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Stanley C. Ruchelman
Chairman
Ruchelman
Mr. Ruchelman concentrates his practice in the area of tax planning for transactional business operations, with... | Read More
Mr. Ruchelman concentrates his practice in the area of tax planning for transactional business operations, with emphasis on intercompany transactions. He represents companies in matters involving the I.R.S. and counsels corporate clients on transfer pricing issues and worldwide reorganizations. He advises foreign private clients on structuring investments in the United States. He authors and speaks on international taxation. Previously, he was an international tax partner at a major international accounting firm and was a senior attorney in the Legislation & Regulations Division of the Office of Chief Counsel, Internal Revenue Service, where he participated in the negotiation of income tax treaties and the development of legislative and regulatory policy affecting international business.
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