Issue 78 - 20 December 2007
Sentiment
Welcome to the last edition of the ITN for 2007. It has been quite some year: we have settled nicely into our new offices (although the proximity to The Fox Club has resulted in some late nights and significant headaches); we have seen old friends move to new pastures (Hema in particular) and been joined by new members of the team (Lara, Hayley and Lynette) who have fitted in perfectly. All in all it has been a great year and we hope to continue our development in 2008 with the appointment of two new senior members of the tax advisory team. More to follow in the New Year. Our client cases have been as varied as I can remember, and we are very grateful to our clients and professional colleagues who keep referring business to us. Keep it coming!
Issue 77 - 27th November 2007
Sentiment
I've never been one to celebrate anniversaries (as Bec my wife will testify, due to the fact I usually forget ours), or get hung up about birthdays, but of late I have to say I have been feeling my age. Zoe in the office has recommended I start to use eye cream as she thinks I have aged dramatically recently, and the middle aged spread has started in earnest.
Issue 76 - 24th October 2007
sentiment
I am sitting in Guernsey airport writing this sentiment, having spent the last few hours debating whether the zero rate of corporate tax to be introduced in Guernsey will have an impact on the validity of the Guernsey / UK double tax treaty. The same argument is applicable to Jersey and the Isle of Man and is an interesting one. For a company to benefit from a double tax treaty it must be resident for tax purposes in a given jurisdiction. If a Guernsey company, for example, is subject to tax, albeit at a rate of zero, is it tax resident for the purposes of the treaty? That’s what has been vexing me today and I think there are valid arguments to say that a treaty won’t apply in such circumstances, or at least will provoke a renegotiation of the relevant UK treaties.
Issue 75 - 5th Sept 2007
Welcome back folks!
What a dismal summer we have had - so much for global warming. It's been a howler here in London, and just as we get back to work the weather picks up. Despite it being quiet on the ITN front we have been ‘busy bees’ at IFS. In addition to lots of client work we have had the website re-vamped and a new-look ITN designed which is launched with this edition. Much has happened on the tax front too – news in the US of a bill which would outlaw “treaty shopping” (although this seems a bit odd to us since most of the US treaties contain anti-treaty shopping provisions).The Italian Ministry of Finance has also issued a welcome Circular on their interpretation of the taxation of trusts (see below), which clarifies a number of issues that have been vexing some of our clients and HMRC has issued a Statement of Practice on the Investment Manager Exemption.
Issue 74 - 9th July 2007
I am writing this not from the South of France, not from Bali, Monaco or from Scarborough but from my small, humble office at home in Notting Hill. I am listening to my favourite band Talking Heads and the best album in the world: Stop Making Sense (if you haven't got a copy go out and buy one now!). We have just had a very enjoyable dinner with our Scandinavian friends who are leaving the garden square next week with their kids to return home. And who can blame them? The weather's rubbish, home security is shot and the tax system, in particular private equity, is under fire. My Norwegian friend is in the private equity / hedge fund industry but he doesn't have a pointed tail and horns sticking out of his head believe it or not!
Issue 73 - 11th May 2007
Reading is an essential element of any tax advisors “homework” – keeping up to date with the latest trends and developments in international tax is important so that we stay in tune with what is happening around the world. Hopefully you, our readers, find the ITN informative and a useful addition to your weekly reading. Just recently I have been ploughing through a fascinating book on the way in which a modern professional advisory firm should function and be managed. One key element is of course how to charge clients for tax advice. The theory posited by the authors is that billing time is an archaic concept which has little relation to the value of the services actually provided. Whether this is true I don't know, but it certainly has some merit. By way of analogy Mercedes or BMW don't price a car simply by reference to the number of hours it takes to make, but by reference to a number of elements, two of which are quality and the value the customer believes the product to be worth. Whether fees are calculated on an hourly basis or value basis, the most important issue is ensuring that we are providing value for money when advising clients.
Issue 72 - 1st May 2007
Oh the joys of parenthood! Tommy, the slightly wild and unhinged youngest member of the Dean brood, has at last succumbed to potty-training. It has been a long, rocky and more often than not smelly and washer/drier intensive experience. He will thank me for writing this in the future, but both he and Jim have - thanks to their cousins, who shall remain nameless (although their parents do receive a copy of this splendid newsletter, so I best go easy), have contracted a dire dose of head-lice, although Jim is pleased as he can impress his girlfriend and skive school.
Issue 71 - 10 Apr 2007
I am pleased to report that I am back from MIPIM in once piece, having spent a very enjoyable weekend in Eze recuperating! I am now in Scarborough for the Easter break and am officially a Southerner, see last ITN. Any claims to being a hardy northerner can no longer be substantiated – a walk along the North Bay, past the now demolished institution that was the Corner Caff, has confirmed that I belong in the South.
Issue 70 - 13 Mar 2007
I am barely back from some winter sun chez family Dean in Sharm el Sheikh and it’s off to Cannes for MIPIM – God help us all! I have been shocked into fitness action having made the schoolboy error of watching the holiday video of T’gypt with my in-laws. It was quite evident that I have been eating lots of pies recently (this is an English expression describing someone who is of the Teletubby persuasion), and the time has come for change.
Issue 69 - 12 Feb 2007
Finally winter has arrived – a couple of centimetres of snow and the UK grinds to a halt; some things never change! I’m also feeling my age – I have been pouring over the first edition of the ITN and was amazed that we are 6 years young this month. A lot of water has gone under the proverbial bridge since our inaugural edition and long may that continue to be the case.
Issue 68 - 19 Jan 2007
Happy New Year to all our readers and friends from everyone at IFS. The first ITN of 2007 has come around as if 2006 never really happened; Christmas and the New Year are a mere blur (literally speaking that is) now, and our focus is on the year ahead. Quite what 2007 has to offer in terms of international tax is anyone’s guess, but one thing is for certain – we are sure to have some surprises along the way. If this year is anything like 2006 the ECJ will have a lot to say, cases will create certainty and uncertainty, close planning opportunities and at the same time create new ones. Our aim this year is to continue where we left off last year and push for more cross border corporate transaction work, together with the offshore fund and alternative asset class planning that kept us busy.
