2019 Mid-Year Review

Warren & Partners has been involved in several interesting assignments during 2019 to date. We wanted to highlight some of these projects and give an insight into our work during the first half of 2019.

‍‍Advising Companies

Our Corporate Tax and VAT team have been involved in several interesting projects, particularly in the area of Corporate Restructuring and Property Transactions.

• We advised on the acquisition and disposal by Irish investors of US commercial property interests held through complex US LLC structures, as well as the tax treatment of any ongoing income and capital gains derived from these investments.  
• We carried out a review of the Irish, UK and German corporate structure and activities of a large Irish family business with a view to making improvements to its group structure in view of its continuing expansion in Europe.
• We assisted several non-resident individuals to establish Irish nominee companies to facilitate the acquisition of Irish investment property and advised these individuals of their Irish tax obligations and filing requirements.  
• We assisted a UK-based property development company with the tax due diligence process in obtaining funding for the development of a large Irish residential development.
• We advised an Irish individual on a restructuring plan in order to streamline and simplify their property development business through an Irish corporate structure.
• We advised on the VAT treatment on the sale of various residential and commercial properties in our client’s portfolio, as well as reviewing Contracts for Sale and Pre-Contract VAT Enquiries from a tax perspective.

Read more about our work with Irish Owner Managed Businesses and International Companies in Ireland.

Private Client Matters

During the first 6 months of 2019, our Private Client Tax Team have completed several assignments related to pension planning and wealth management for high net worth individuals.

Over the past few months, we have seen an increased number of Senior Executives employed with large multinationals seeking tax advice independently from their employer.  We have assisted Senior Executives in identifying their tax obligations and filing requirements in respect of any company share schemes and remuneration.  However, seeking independent tax advice has proved beneficial for many clients in considering more long-term wealth management and retirement planning.  In this regard, we have provided comprehensive tax planning advice to Senior Executives which considered various options for future investment and retirement.

Read more about our Private Client services.

Inheritance and Gift Tax Planning

Our Estate and Trust Planning Team saw continued interest in clients seeking advice in respect of tax efficient estate planning, particularly for passing assets to the next generation.  

We advised clients (operating through a corporate vehicle) on the tax implications of gifting “flowering shares” to their children and ensured that this plan was implemented correctly.

We also advised on tax efficient options for passing a family business (operating as a sole trade) to the next generation, while maximising any gift or inheritance tax reliefs available.

We have continued to advise and implement tax efficient wills for clients to ensure that wealth is passed to the next generation in the most efficient manner.

Read more about our Inheritance & Gift Tax services.

Revenue Engagement

In recent years, we have noted a significant increase in the number of interventions by Revenue with both corporate and personal clients. In the first half of 2019, we provided advice on various types of Revenue interventions from Aspect Queries to engaging in the tax appeals process with the Tax Appeals Commission.

• We have assisted many clients with non-audit compliance interventions, such as Aspect Queries.
• We carried out a VAT, PAYE and Income Tax self-review for a family business ahead of a Revenue Audit.
• We assisted corporate and personal clients in preparing Voluntary Disclosures (in preparation for a Revenue audit or otherwise).
• We engaged in negotiating settlements with Revenue on behalf of clients in respect of ongoing Revenue audits.
• We have engaged with the tax appeals process and assisted clients and their Legal Counsel in preparing for their case with the Tax Appeals Commission.

Read more about our Revenue Engagement services.

Network Development

Our clients are increasingly looking for advice on a range of matters under one roof.  In order to provide more comprehensive advice to our clients on a range of issues, we have developed relationships with advisers who specialise in areas outside of tax, such as pension and financial planning.  Our network of advisers keeps us up to date with developments in their field that may be of interest to our clients and are happy to assist our clients with any specific issues as part of a collaborative engagement.

While Warren & Partners specialise in providing Irish tax advice to corporate and private clients, we are cognisant that tax is continuing to be an area of increased international scrutiny.  Now, more than ever, clients need to be aware of developments in tax laws in other jurisdictions that may have an impact personally or to their business. Over the past few months, we have developed rapport with tax advisers in many jurisdictions such as the UK, Germany and the United States.  In developing these relationships, we now have easy access to experienced tax professionals in many jurisdictions.