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The Bermuda Government is consulting on the introduction of a corporate income tax, a significant policy shift driven by the OECD’s Pillar Two global minimum tax rules, known as the GloBE Rules.
This move aims to align Bermuda with international tax standards and mitigate the impact of top-up taxes under the GloBE framework.
The proposal responds to the GloBE Rules, which apply a top-up tax when the effective tax rate in a jurisdiction is below 15%. The new tax regime in Bermuda is designed to ensure that taxes paid by Multinational Enterprise Groups (MNEs) in Bermuda are accounted for under the GloBE Rules.
The Bermuda Government is considering a corporate income tax rate between 9% and 15%, aiming to avoid exceeding an overall 15% effective tax rate for MNEs operating in Bermuda.
The tax would primarily affect Bermuda businesses that are part of MNEs with annual revenue exceeding €750M.
Certain sectors, such as not-for-profit groups, pension funds, and investment funds, would be exempt from this corporate tax.
Provisions for tax credits and qualified refundable tax credits, as defined in the GloBE Rules, will be included in the new tax regime.
Most Bermuda entities, especially those with annual revenues below €750M, will not be affected by the new tax.
The Bermuda Tax Reform Commission is exploring restructuring existing tax regimes to reduce living and business costs on the island.
The first consultation period runs from August 8 to September 8, 2023. Interested parties can submit comments through the government’s website or through legal contacts in Bermuda.
A more comprehensive second consultation is planned for later in the year to address specific aspects of the proposals, including scope, tax computations, and transitional matters.
The introduction of a corporate income tax in Bermuda marks a shift towards global tax compliance standards.
The new tax regime will affect how MNEs structure their operations and tax strategies, particularly those with significant activities in Bermuda.
Bermuda’s government must balance the new tax regime’s implications for the local economy with international tax obligations.
Bermuda’s potential introduction of a corporate income tax signifies a notable adaptation to the global tax landscape, particularly in response to the OECD’s GloBE Rules.
It also highlights the increasing international pressure on tax havens to comply with global minimum tax standards, and it underscores the need for MNEs to reassess their tax strategies in light of evolving international tax policies.
If you have any queries about this article on Bermuda Corporation Income Tax, or Bermuda tax matters in general, then please get in touch
A significant development occurred on 19 December 2023 with the US Treasury Department’s announcement of the activation of the US-Chile Tax Treaty.
This Convention, formally known as the Convention Between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital – a bit of a mouthful! – marks a milestone as the first new U.S. tax treaty in over a decade.
Initiated in 2010, the treaty faced an extensive delay in the U.S. Senate, primarily due to aligning it with the 2017 Tax Cuts and Jobs Act’s (“TCJA’s”) radical changes.
Finally, in July 2023, the Senate gave it the nod, incorporating two crucial TCJA-related reservations.
This ratification opened doors for Chile, positioning it as the first nation to establish a new tax treaty with the U.S. in this era.
The Treaty introduces significant reductions in withholding taxes across various domains:
For dividends issued by a U.S. corporation to a Chilean owner, the withholding rate is generally reduced to 15%.
It further drops to 5% if the recipient is a company holding a minimum of 10% of the voting stock.
Interest payments see a withholding tax cut to 15% for the first five years, post-Treaty enforcement, and 10% thereafter. Notably, for certain beneficiaries like banks and insurance companies, this rate is as low as 4%.
The Treaty caps the withholding tax on royalties at 10%, with specific exceptions.
Residents of either country selling shares in the other’s companies are taxable only in their resident nation, subject to meeting certain criteria.
Additionally, the Treaty introduces a limitation-on-benefits provision to curtail treaty shopping, aligning with U.S. treaty practices.
The Senate’s ratification came with two critical reservations, later approved by Chile’s National Congress, ensuring the Treaty’s compatibility with the TCJA:
The Treaty’s provisions on withholding taxes will be applicable to payments made or credited from 1 February 2024, onwards.
Other tax provisions will be effective for tax years starting 1 January 2024.
Additionally, the provisions for information exchange are effective immediately.
The US-Chile Tax Treaty is important as it potentially creates a template for future US tax treaties.
For persons effected by the new treaty, understanding and potentially leveraging its benefits of will be key to optimising cross-border operations.
If you have any queries regarding this article on the US-Chile double tax treaty, or US or Chile tax matters in general, then please get in touch.
If you have any queries about this article on New Zero Tax Rate on Photovoltaic Systems in Germany, or German tax matters in general,than please get in touch.
On 5 December 2023, Saudi Arabia unveiled a significant tax incentive program for Regional Headquarters (RHQs), marking a strategic move to attract foreign companies and investments.
This announcement, involving a tax holiday and withholding tax exemptions, is set to bolster Saudi Arabia’s position as a regional business hub.
RHQs will benefit from a 30-year tax holiday, offering substantial savings and financial advantages.
Payments made by RHQs will be exempt from withholding taxes, further enhancing the financial benefits of establishing an RHQ in Saudi Arabia.
– While the broad framework of the tax incentives has been announced, specific details regarding eligibility, compliance procedures, and anti-abuse measures are still forthcoming. These details are crucial for companies to understand the full implications and requirements of the program.
This tax incentive package positions Saudi Arabia as an attractive destination for multinational corporations looking to establish RHQs in the region.
Companies with existing RHQ licenses or those considering setting up RHQs in Saudi Arabia will need to reassess their business strategies and plans in light of these new incentives.
It is anticipated that relevant Saudi regulatory agencies will soon publish comprehensive rules outlining the incentive package. This will include information on eligibility criteria, reporting obligations, filing requirements, and measures to prevent abuse.
The introduction of these tax incentives is expected to significantly impact the regional business landscape, potentially leading to increased foreign investment and corporate activities in Saudi Arabia.
Saudi Arabia’s introduction of a 30-year tax holiday for RHQs, coupled with withholding tax exemptions, is a bold initiative aimed at enhancing the country’s appeal as a key player in the regional economy.
Foreign companies and investors should closely monitor the release of further details to capitalize on these incentives and align their operational strategies accordingly.
This move demonstrates Saudi Arabia’s commitment to fostering a conducive business environment and attracting global business presence.
If you have any queries about this article on Saudi Arabia Regional Headquarters Program, or Saudi Arabia or GCC tax matters in general, then please get in touch.
On 16 October 2023, the Council of Ministers preliminarily approved a legislative decree proposing significant reforms to international taxation in Italy.
This decree is currently undergoing review by relevant parliamentary committees before it officially becomes law.
An interesting proposal is a relief for the so-called ‘reshoring’ of economic activities.
Let’s look at this in some more detail.
Expected to come into force after final approval of the legislative decree (anticipated by December 31, 2023), the ‘reshoring’ provisions aim to rejuvenate Italy’s economic landscape.
However, their actual enactment hinges on authorization from the European Commission.
Article 6 of the draft legislative decree outlines a specialized tax incentive designed to incentivize the transfer of ‘economic activities’ to Italy.
Unlike similar measures in other nations, Italy’s decree extends beyond specific sectors, aiming to encompass ‘economic activities’ regardless of industry.
Under the proposed measure, income derived from business activities transferred from non-EU or non-EEA countries to Italy will enjoy a 50% exemption from income tax and IRAP (Regional Production Tax) for a designated period:
The relief spans the tax period during the transfer and the following five tax periods. However, ‘economic activities’ already conducted in Italy within the preceding 24 months are excluded from eligibility. Interpretive Challenges and Scope The decree poses several questions for stakeholders, primarily concerning its application scope.
The term ‘economic activities’ casts a wide net, referencing income from business activities conducted in non-EU/EEA countries and relocated to Italy.
This suggests potential application scenarios, including the relocation of non-EU/EEA companies’ registered offices to Italy.
Though the draft decree doesn’t explicitly mention the combined application of ‘reshoring’ relief and tax basis adjustment provisions, such as Article 166-bis of the Consolidated Income Tax Law (TUIR), experts opine that these could complement each other.
This combination might lead to higher depreciation or lower capital gains, further reducing the taxable base.
Determining the application of ‘reshoring’ relief, along with compliance with other provisions like ‘Pillar 2’ and ‘Qualifying Domestic Minimum Top-Up Taxes,’ poses intricate challenges.
The definition of ‘economic activity’ under European Union law highlights the complexity of identifying eligible activities.
Moreover, entities already established in Italy undergoing functional changes might potentially qualify for ‘reshoring’ benefits.
This includes transformations within the value chain, such as a distributor evolving into a manufacturing entity.
To benefit from the incentive, taxpayers must maintain meticulous accounting records to verify income determination and eligible production values.
The legislation stipulates forfeiture conditions, triggering the recovery of unpaid taxes in case of activity transfer out of Italy within specific periods following ‘reshoring.’
Italy’s proposed tax incentive for ‘reshoring’ economic activities presents opportunities and complexities for businesses.
The legislation’s interpretation and application nuances warrant thorough understanding, and compliance measures are crucial to harness the benefits while navigating the regulatory landscape effectively.
If you have any queries around Italy and reshoring of economic activities, or Italian tax matters in general then please get in touch.
The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article.
Singapore’s physical landscape has changed significantly over the last decades as it has become a global hotspot for finance and wealth.
However, it appears that their tax vistas are similarly developing too!
In a significant development in Singapore’s tax landscape, the upcoming implementation of section 10L within the Income Tax Act 1947 (“new section”) is poised to introduce a crucial alteration to the taxation of gains arising from the sale or disposal of foreign assets.
This legislation, set to take effect from 1 January 2024, has spurred substantial discussion within the Singapore tax community. This is due to its potential implications for the taxation of capital gains, historically untouched by Singapore’s tax regime.
The introduction of the new section has prompted a vital need for multinational corporations (MNCs) and businesses to comprehend its far-reaching tax implications.
This remainder of this article aims to provide an in-depth understanding by delving into the rationale behind its implementation, outlining its key features, and offering insights into its potential impact.
According to the official reports from Parliamentary Debates, the primary objective behind the introduction of the new section is to address international tax avoidance risks related to gains from disposals, particularly when such gains arise without substantial economic activities.
This legislative move aligns with Singapore’s commitment to international standards and frameworks against harmful tax practices, such as the rules formulated by the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) and the EU Code of Conduct Group Guidance, of which Singapore is an active participant.
Notably, Singapore clarified in official reports that the fundamental aim of this amendment is not to tax capital gains specifically.
The new section will tax gains received in Singapore from the sale or disposal of foreign assets, treating them as income subject to tax.
However, certain exceptions exist, such as exemptions for entities demonstrating “adequate economic substance” in Singapore and those with operations managed and performed within the country.
Entities that are part of a group solely operating or incorporated in one jurisdiction, or certain entities engaging in specific activities, may also be exempt.
Moreover, the taxable amount will be the net gain received in Singapore, and the section applies to disposals occurring on or after 1 January 2024.
Its introduction represents a positive step in addressing international tax avoidance and aligning with global norms.
However, despite official clarifications asserting that the amendment is not intended to tax capital gains, the precise interpretation of the legislation remains uncertain.
The absence of explicit exclusion for capital gains in the section’s wording raises questions about its practical application.
Furthermore, uncertainties surround the interpretation of terms such as “adequate economic substance,” necessitating more detailed guidance from the tax authorities. Seeking Advance Rulings might be advisable for transactions of significant economic value to gain clarity.
While increased record-keeping requirements are anticipated, efforts are underway to minimize the compliance burden through collaboration between the tax authority and industry players.
The impending implementation of section 10L brings forth a period of ambiguity for MNCs and businesses regarding its interpretation and application.
Seeking legal counsel and guidance will be prudent to navigate potential challenges arising from this new legislation.
As Singapore continues to evolve its tax framework in line with global standards, the successful implementation of the new section hinges on the clarity and guidance provided by the authorities to ensure a smooth transition and compliance for businesses operating within its jurisdiction.
If you have any queries relating to Singapore’s New Policy on Foreign Asset Gains, or Singaporean tax matters more generally, then please do not hesitate to get in touch.
The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article.
The Finance Bill for 2023, published on 19 October, brings forth significant changes and updates in the Irish financial landscape.
This bill primarily focuses on implementing the Pillar 2 regime, setting a minimum effective tax rate of 15% into Irish law, among other noteworthy provisions.
Here’s a summary of some of the key changes and their implications.
As expected, the Finance Bill transposes the EU Directive on ensuring a global minimum level of taxation, often referred to as the “Pillar 2 Directive.”
This directive sets a minimum effective tax rate of 15% into Irish law.
This change will have a significant impact on large multinationals with a global turnover exceeding €750 million and wholly domestic groups within the EU.
It involves the introduction of “GloBE” rules, consisting of an income inclusion rule (IIR) and an Under Taxed Payment Rule (UTPR).
The IIR takes effect for fiscal years starting after 31 December 2023, and the UTPR will broadly apply for fiscal years starting after 31 December 2024.
The Finance Bill introduces transitional and indefinite safe harbors to alleviate the compliance burden.
The qualified domestic minimum top-up tax (QDMTT) is one such provision, which aims to allow Ireland to apply a domestic top-up tax for Irish constituent entities.
This will potentially reduce the tax calculation and payment obligations for in-scope groups.
Ireland has also adopted other safe harbors following the OECD’s guidance.
To prevent double non-taxation of income, the bill introduces measures denying withholding tax exemptions in certain situations.
These measures primarily apply to payments of interest, royalties, and distributions to associated entities in jurisdictions that are not EU Member States and appear on the EU list of non-cooperative or zero-tax jurisdictions.
New rules are introduced for interest deductibility for “qualifying financing companies” with specific criteria.
These rules generally apply when such companies own 75% or more of the ordinary share capital of a “qualifying subsidiary” and borrow money to on-lend to the subsidiary.
The R&D tax credit is enhanced by increasing the rate from 25% to 30% of qualifying expenditure for accounting periods beginning on or after 1 January 2024.
This change aims to maintain the credit’s net value for companies under the new Pillar 2 regime while providing a real increase in the credit for SMEs.
A pre-notification requirement and other information requirements for R&D claims are introduced as well.
Adjustments are made to the operation of the digital gaming credit to align with the new Pillar 2 definition of a non-refundable tax credit.
These changes affect the manner and timeline for credit payments.
From 1 January 2024, the mechanism for taxing gains from share options shifts from self-assessment by employees to being the responsibility of employers through the Pay As You Earn (PAYE) system.
The bill introduces capital gains tax relief for angel investors in innovative SME start-ups.
Detailed wording for this relief is expected to be included later.
The EIIS is amended to standardize the minimum holding period for relief at four years.
The limit on the amount that an investor can claim for such investments is increased from €250,000 to €500,000 per year of assessment within four years.
An exemption from Irish Stamp Duty for American depository receipts (ADRs) is extended to include transactions in DTC of US-listed shares.
This exemption streamlines the process and eliminates the need for Revenue clearance, making it more efficient.
The Finance Bill transposes EU Directive DAC 7, allowing for cross-border audits with other EU Member States.
It also clarifies Revenue’s authority to make inquiries under the Mandatory Disclosure Regime.
The Finance Bill 2023 introduces numerous significant changes in Irish tax and financial regulations.
Businesses should carefully assess and adapt to these changes to ensure compliance and minimize tax implications effectively.
As always, consulting with financial experts is crucial to navigating these complex tax reforms.
If you have any queries about Ireland Finance Bill 2023, or Irish tax matters in general, then please do get in touch.
The Central Board of Direct Taxes (CBDT) announced changes to the so-called Angel Tax provisions.
It did this through a notification dated 25 September 2023.
The notice has made amendments to Rule 11UA of the Income-tax Rules, 1962, which outline the methodology for calculating the fair market value (FMV) of unlisted equity shares and compulsorily convertible preference shares (CCPS) under Section 56(2)(viib) of the Income-tax Act, 1961.
Section 56(2)(viib) is commonly known as the “Angel Tax” provision.
The Angel Tax provisions apply when a company not substantially owned by the public (private or unlisted public company) issues shares at a premium that exceeding the FMV of the shares.
The excess amount received is treated as income from other sources.
Prior to April 1, 2023, Angel Tax applied only to shares issued to Indian tax residents but now extends to shares issued to non-residents.
The amendments introduce flexibility in valuation methods and incentivize venture capital investments, with the following notable provisions:
Types of Valuation Methods: The issuer company can choose from various valuation methods, including new methods for non-resident investors and venture capital investments
Methods for Non-Resident Investors: Five new valuation methods (e.g., Comparable Company Multiple Method) have been introduced for shares issued to non-resident investors. These methods must be computed by a Category I merchant banker registered with the Securities and Exchange Board of India (SEBI).
Methods for Venture Capital Undertakings: The FMV of equity shares issued to venture capital investors can be used as a benchmark for shares issued to other investors within a specific period.
Methods for Notified Investors: The valuation method for unquoted equity shares issued to Notified Investors is used as a benchmark for shares issued to other investors within a set period. Notified Investors are specified in Notification No. 29/2023 dated May 24, 2023.
Valuation of CCPS: The FMV of CCPS can be determined using the DCF method or new valuation methods based on the type of investor or FMV of unlisted equity shares.
The valuation date allows the use of a valuation report issued up to 90 days before the date of share issuance.
A safe harbour provision permits a tolerance limit of 10% between the issue price and FMV.
If the difference does not exceed 10%, the issue price is considered the FMV.
The Angel Tax provisions also apply to startups receiving investments from non-residents, with exceptions based on specified conditions.
While these measures are welcomed, Indian companies continue to face scrutiny regarding share premiums and valuation methods.
An observation is that Indian tax authorities often challenge valuation methodologies and assumptions, focusing on increasing the tax base by treating undervalued share issuances as income from other sources.
If you have any queries about the Changes to the Angel Tax Valuation Rules, Indian tax, or tax matters in general, then please get in touch.
In a bid to take substantial strides towards its climate goals, the Dutch government unveiled a series of legislative proposals and amendments concerning energy and environmental taxes on Budget Day.
These measures are geared towards reducing the Netherlands’ greenhouse gas emissions by a commendable 55% by 2030, in alignment with the government’s climate ambitions.
However, it’s essential to bear in mind that these proposals are subject to discussions, amendments, and adoption by the Dutch parliament.
This article provides an in-depth look at some of those proposals covering:
From 1 January 2024, the energy investment deduction (EIA) rate will undergo a reduction, declining from 45.5% to 40%.
Additionally, the sunset clause for energy and environmental deductions has been extended until 2028, implying that they will remain in effect, at least until that time.
As of 1 January 2025, the energy tax exemption for electricity and gas used in metallurgical and mineralogical processes will be eliminated.
The Dutch government views these exemptions as fossil subsidies, which no longer align with the nation’s climate objectives.
In addition, a new energy tax exemption will be introduced on 1 January 2025, for the supply of electricity used in hydrogen production via electrolysis.
This exemption is confined to electricity utilized directly in the water-to-hydrogen conversion process, encompassing activities like demineralization, electrolysis, and the purification and compression of resulting hydrogen.
Starting January 1, 2025, several changes are proposed regarding exemptions for electricity production, including cogeneration.
Key changes include:
The reduced energy tax rate presently applicable to the greenhouse horticulture sector will be gradually phased out, commencing on 1 January 2025, and concluding in 2030.
Effective from 1 January 2024, a new, lower bracket in the energy tax will be introduced for both electricity and gas.
This bracket will cover the first 2,900 kWh of electricity and 1,000 m3 of gas.
This adjustment is intended to provide the government with the flexibility to reduce energy tax for households when necessary, aligning with the current price cap for households.
Various changes will be made to tax regulations for block heating, designed to accommodate the modifications in tax brackets mentioned above.
Starting January 1, 2024, the Dutch minimum carbon tax prices for the industrial and electricity generation sectors will rise. Despite these increases, the government anticipates no budgetary implications, given the existing EU ETS price. The new minimum prices are as follows:
Commencing January 1, 2025, a carbon tax will be introduced for CO2 emissions in the greenhouse horticulture sector, mirroring the current system in place for the industrial sector.
This development coincides with the introduction of specific EU ETS obligations for the built environment.
With effect from 1 January 2028, the coal tax exemptions for dual coal use and coal utilization for energy production will be discontinued.
The current coal tax rate stands at EUR 16.47 per metric ton.
New information obligations will be incorporated into specific energy tax regulations to align with the European Commission’s guidelines on State Aid for climate, environmental protection, and energy.
Commencing on 1 January 2024, these rules will encompass principles for providing data and information, upon request, to comply with EU obligations.
The Dutch government’s commitment to climate goals is evident in these proposed tax changes, which seek to incentivize eco-friendly practices while gradually phasing out less sustainable measures.
These proposals will be closely monitored as they make their way through the legislative process, potentially reshaping the landscape of energy and environmental taxation in the Netherlands.
If you have any queries about the Netherlands’ Green Budget, or Dutch tax in general, then please get in touch.
Last month, the Canadian federal government introduced a draft legislation package known as the August Proposals.
These proposals encompass a range of revisions to amend the Income Tax Act, with a key focus on the introduction of a novel equity repurchase tax.
Set to take effect on 1 January 2024, this tax is poised to impact numerous publicly traded entities, subjecting them to a 2% levy on the “net value” of specific equity repurchases.
The equity repurchase tax applies to a broad array of publicly traded entities. This includes Canadian-resident corporations (excluding mutual fund corporations), as well as certain trusts and partnerships, collectively referred to as Covered Entities.
Key points to understand about the equity repurchase tax:
The origins of this equity repurchase tax can be traced back to the 2022 Fall Economic Statement. It was here that the Canadian government initially revealed its intention to introduce a 2% corporate-level tax on the net value of share buybacks by Canadian public corporations.
This tax bears similarity to the 1% share buyback tax enacted in the United States under the Inflation Reduction Act of 2022.
Budget 2023 provided more comprehensive legislative proposals, extending the tax’s scope to encompass specific publicly traded trusts and partnerships, thus expanding its reach.
It also clarified that normal course issuer bids and substantial issuer bids would be considered equity repurchases for tax purposes.
The equity repurchase tax relies on a netting rule formula: 0.02 x (A – B), where:
This netting rule applies annually, corresponding to the Covered Entity’s fiscal year, for repurchases and issuances occurring after 1 January 2024.
Importantly, there are no grandfathering rules, meaning that equity outstanding prior to this date, but repurchased afterward, remains subject to the tax.
Moreover, any excess in Variable B over Variable A cannot offset repurchases included in Variable A in subsequent years.
To determine the equity repurchase tax, the calculation considers repurchases and issuances of equity by a Covered Entity.
However, not all equity is included; the tax excludes equity that exhibits “substantive debt” characteristics. Substantive debt equity is defined as:
Many preferred shares may not meet the criteria for substantive debt, such as convertible preferred shares and voting preferred shares.
Since there are no grandfathering rules, Covered Entities with issued and outstanding preferred shares must evaluate whether their shares qualify as substantive debt for tax purposes.
Variable A includes the fair market value of equity (excluding substantive debt) repurchased by the Covered Entity in a taxation year.
Certain equity acquisitions by specified affiliates of a Covered Entity are also included.
However, the deeming rule does not apply to specified affiliates that are registered securities dealers acting as agents for customers or certain employee benefit trusts.
Exceptions to Variable A include specific reorganization transactions, such as share-for-share exchanges and tax-deferred amalgamations, winding-up of the Covered Entity, and other tax-deferred transactions.
Variable B includes the fair market value of equity (excluding substantive debt) issued by a Covered Entity. Equity issuances are included only if:
An anti-avoidance rule applies to prevent transactions aimed at decreasing the total value of equity repurchased or increasing the total value of equity issued, primarily for tax avoidance purposes.
The August Proposals introduce a de minimis threshold of $1 million. The tax is not applicable if Variable A is less than $1 million in a taxation year. This threshold is calculated on a gross basis without considering the netting rule and the value of equity issuances in Variable B.
Covered Entities repurchasing equity in a taxation year must file a return and, if applicable, pay the equity repurchase tax.
Filing and payment deadlines vary for corporations, trusts, and partnerships, with specific timelines outlined for each entity.
In summary, the introduction of Canada’s new equity repurchase tax marks a significant development in the country’s tax landscape.
Understanding its intricacies and ensuring compliance is crucial for publicly traded entities, as non-compliance can result in financial penalties.
If you have any queries about this article on Canada’s new Equity Repurchase Tax, or Canadian tax matters in general, then please get in touch.
The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article.