Warren & Partners ~ 21-Dec-2018

Looking back on 2018

2018 is about to end and we wanted to share with you some of our notable experiences in the course of the year.

Advising Companies

2018 has been a busy year in our Corporate Tax Transactions and Planning Team. We provided tax advice on a number of matters, including the following:

  • We advised a foreign listed company on the tax efficient acquisition of an Irish trading company and its valuable intellectual property. We subsequently advised on the acquired company’s change in tax residence to minimise the exit tax implications of the change.
  • We advised the shareholders of a US parent and Irish tax resident subsidiary company, operating in the pharma sector, on its sale to a European listed company.
  • We advised on the sale of a large retail park (held via a complex ownership structure) to an Irish domestic pension fund.
  • We advised on the sale by Irish investors of US commercial property interests held through US LLC structures, to minimise the effective rate of capital gains tax suffered by investors in the US and Ireland.
  • We restructured a number of corporate groups in advance of numerous events, including refinancing, management buy outs/ins, share sales and capital investment.

Read more about our Corporate Tax services.

Inheritance and Gift Tax

Our Estate and Trust Tax Planning Team have experienced significant growth in the demand from clients for advice on inheritance and gift tax planning issues, predominately related to the tax efficient transfer of assets to the next generation.

Whether it has been the implementation of tax efficient wills, family partnership structures or domestic trust structures, the continued increase in the value of assets, coupled with the reduction in the number of legacy bank debt issues, has created an environment for the transfer wealth efficiently to the next generation.

We have also seen an increase in the number of requests for advice on cross jurisdictional trust and estate tax issues, in particular the interaction between tax rules in Ireland, the UK and US.

Read more about our Inheritance & Gift Tax services.

Private Client Matters – Remittance Basis of Tax and related matters

During 2018, our Private Client Tax Team saw continued interest in non-domiciled foreign resident individuals moving to Ireland and availing of the remittance basis of tax here. Typically, such individuals are moving to Ireland from the US, the EU and a growing number from the UK (partly because of Brexit).

To assist clients, we have developed excellent relationships with investment brokers within and outside Ireland, to enable non-domiciled individuals who seek to avail of the remittance basis of tax in Ireland, put together an efficient investment strategy.

For those entrepreneurs seeking to build on business relationships across the globe, we are seeking increased demand for support with planning their move abroad.

Read more about our Private Client services.

Global Mobility Tax Services

As our corporate clients expand abroad or move into Ireland, we advise on the tax issues associated with either posting key employees abroad or assigning executives or employees to work in Ireland.

We work with corporate clients to ensure the Irish payroll costs associated with these moves are kept to a minimum by utilising various tax reliefs such as Special Assignee Relief Programme (SARP), PAYE Exclusion Order, Split Year Residence Relief, Foreign Earnings Deduction (FED) and Cross Border Worker (Transborder) relief.

Read more about our Global Mobility Tax service.

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Please note: The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation.