Jillian Rosansky’s Post

Do you know the characteristics, obligations, and recommendations of the Annual Informative Declaration of Transactions with Third Parties (Model 347)? #obligations #taxagency

Our latest newsletter is now available!😁 The new regulation of Law 5024/2023 amended inter alia the tax treatment of the contribution of securities of a natural person to a legal entity in case the contributor is the sole shareholder of the recipient. Pursuant to the new provision, capital gains tax is no longer imposed on a natural person at the time of the contribution, since the acquisition price of the contributed securities is considered as selling price, provided that the individual who contributes the securities receives in return the total number of shares or company parts (100%) issued by the recipient. Find out more about non-imposition of capital gains tax on the contribution of securities of natural persons. #VDILawFirm #capital #capitalgainstax #newregulation https://shorturl.at/bkNTU

📢 Alec McCarthy shares insights on the sale of shares to a personal company, with a focus on transaction in securities repercussions. Our VIP advice line receives constant calls about Business Asset Disposal Relief and TIS rules. Thanks to our VIP Tax team's consultancy, clients have been able to evaluate their position with relation to these rules and reliefs. #taxlaw #transactionsinsecurities #businessassetdisposalrelief #VIPtaxteam

If you have questions about transfer pricing method selection, or how transfer pricing methods apply to various types of transactions, then you won’t want to miss this week’s Tax Thursday webinar, “Transfer Pricing Methods.” Register here: https://lnkd.in/en5YThmc  #TaxThursday #TransferPricing #TransferPricingCompliance #CPEcredit #TaxEducation #GlobalBusiness

The rapid pace of change in the International Tax and Transfer Pricing landscape doesn’t show signs of slowing down. Review 2023 transfer pricing tax developments during the TaxWatch webcast next Thursday at 12 PM ET. Participants can earn CPE credit. #InternationalTax #TransferPricing

Deferred Exchange Agreement Using QUALIFIED TRUST Deferred Exchange Agreement Using Qualified Trust so what’s being DEFERRED for TAX PURPOSES because when doing a transaction let’s say for real estate WITH A QUALIFIED TRUST you have a right to a TAX FREE EXCHANGE…which means a beneficiary can choose to NOT SELL A PROPERTY FOR CASH but simply exchange the PROPERTY for OTHER REAL PROPERTY OF LIKE KIND and at that point the EXCHANGOR and BENEFICIARY enter into an EXCHANGE AGREEMENT with respect to the PROPERTY… and a TEUST is created to SECURE ITS OBLIGATIONS within the exchange agreement making the exchange TAX-DEFERRED

The rapid pace of change in the International Tax and Transfer Pricing landscape doesn’t show signs of slowing down. Review 2023 transfer pricing tax developments during the TaxWatch webcast next Thursday at 12 PM ET. Participants can earn CPE credit. #InternationalTax #TransferPricing

Move assets offshore without paying CGT tax. Using an in-specie transfer with clients that have built up portfolios in taxable jurisdictions can save them hundreds of thousands in unnecessary tax bills. An in-specie transfer is shifting assets from one account to another as they are (in-specie). This avoids the needs to sell down into cash and withdraw/deposit cash into each account. Preventing the selling of the assets ensures the client isn't triggering a taxable event and subjecting themselves to capital gains tax. Next time you're moving assets from A to B it is worth considering using this method. #MoveAssetsOffshore #CGTTaxSavings #InSpecieTransfer #TaxEfficiency #TaxPlanning #WealthManagement #CapitalGainsTax #OffshoreInvesting #AssetTransfer #TaxSavingsStrategy #PortfolioManagement #TaxableJurisdictions #TaxBenefits #FinancialPlanning #GlobalOpportunities #WealthPreservation #AvoidTaxation #SavingsStrategies #AssetManagement #ClientBenefits #CapitalGainsStrategy #TaxEfficientTransfers #MaximizeReturns #MinimizeTaxes #SmartInvesting #InheritancePlanning #TaxMinimizationStrategy #FinancialFreedomGoals #AssetAllocationPlan

Based on the IRS notices issued to date, I think it very unlikely that the proposed regs will address whether a private equity partnership holding controlling interests in portfolio corporations will be treated as part of the section 52(b) group. If that is true, how many corporations will be subject to CAMT or will have to go through a series of computations first? Whatever that number is, it should be very much smaller than what would happen if a large group of unrelated corporations owned by private equity partnerships were aggregated in testing for applicable corporation status under CAMT. If that is the case, does the time expended by the IRS on this project justify the end result?

For those impacted by the new capital gains tax (CGT), figuring out its effect on your finances can be tricky. Check out our interactive calculator to help you estimate your potential CGT liability. Explore our info hub for a comprehensive overview of the new tax: https://pwc.to/3RIHsF5 #CapitalGains #CGT #IncomeTax