Roger Muray partner Ernst & Young LLP considers the implications of the draft worldwide debt cap legislation with emphasis on the implications for groups carrying on financial services business
2008 was a year of surprises. The draft legislation on a worldwide debt cap was expected. But after the proposed controlled company legislation planned to replace the CFC rules was abandoned on grounds of complexity and the excessive compliance burden it would impose it is at least a little surprising that the draft worldwide debt cap legislation has similar characteristics. This is not a consequence of matters of detail that can readily be corrected in the course of consultation. It is inherent in the design.
In this article I will explore:
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Roger Muray partner Ernst & Young LLP considers the implications of the draft worldwide debt cap legislation with emphasis on the implications for groups carrying on financial services business
2008 was a year of surprises. The draft legislation on a worldwide debt cap was expected. But after the proposed controlled company legislation planned to replace the CFC rules was abandoned on grounds of complexity and the excessive compliance burden it would impose it is at least a little surprising that the draft worldwide debt cap legislation has similar characteristics. This is not a consequence of matters of detail that can readily be corrected in the course of consultation. It is inherent in the design.
In this article I will explore:
● ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
