Greg Jones considers the fate which may await the UK’s super rich following this week’s UK General Election…

Well, wouldn’t most of us like at least to try, if we’re honest?

Yet although the number of billionaires around the world is on the increase, (as inflation gradually erodes the value of money over time) there is a risk they may become an endangered species.

Labour MP Lloyd Russell-Moyle thinks they shouldn’t exist.

Read more: Who wants to be a Billionaire?!

As investor interest in qualified opportunity zones (“QOZ”) grows, both qualified opportunity funds (“QOFs”) and investors should be aware of the benefits of organizing QOFs as C-Corporations. C-Corporation QOFs may take advantage of the reduced corporate income tax rate of 21 percent and the benefits under Section 1202 of the Internal Revenue Code (the “Code”).

Read more: Qualified Opportunity Zones–Benefits of Using C-Corporation Structure

Multinational enterprises (“MNEs”) with premises/operations in Uruguay and with a worldwide gross income in excess of EUR 750 million per year, must submit to Uruguay's Tax Office a Country-by-Country report (“the CbC report”) to be prepared along the OECD guidelines. Such report must contain detailed information on the branches and other MNE related entities around the world.

Read more: Country by Country Report for Enterprises in Uruguay with 31 December 2019 as Closing Date

Originally published in the California Tax Lawyer, Vol. 28, Issue 2

Authors: Kyle Recker and Alexander Loshiloff


Effective on December 22, 2017, as part of the Tax Cuts and Jobs Act, Congress enacted Sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code.1 Section 1400Z-1 allows the chief executive officer of each state and United States possession to nominate a limited number of primarily low-income population census tracts for designation as “qualified opportunity zones” (“QOZ”), and it authorizes the Secretary of the Treasury to certify such nominations and officially designate QOZs across the United States and its possessions. Section 1400Z-2 offers, under certain conditions, significant tax benefits to taxpayers who invest in QOZs.

Read more: Qualified Opportunity Zones: An Uneasy Path to Significant Tax Benefits

The Spanish General Directorate of Taxation concluded in its binding consultation V1069-19 of 20 May 2019 the obligation for tax non-residents in Spain to pay taxes for the sale of "bitcoins" in exchange for Euros in those cases in which the depository entity is located in the Spanish territory.

Read more: Should a Spanish Tax Non-Resident be Entitled to Pay Taxes in Spain for the Sale of Bitcoins in...