Unified Funds
Tax Exemption Ordinance ) and sets outs intended IRD
practice in administering the Unified Funds Tax Exemption which
came into effect on April 1, 2019.
The Unified Funds Tax Exemption
The Unified Funds Tax Exemption seeks to exempt hedge funds,
including OFCs and LPFs, from Hong Kong profits tax. This exemption
may apply regardless of the fund structure, location of the
fund s central management and control, fund size or fund
purpose provided that prescribed conditions are satisfied.
Unlike the Offshore Funds Exemption, there is no longer a bias
against Hong Kong. Firstly, there is no longer any need to
artificially maintain fund management and control overseas.
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Federal Court in Georgia Applies
Hoover Rule Finding that Insurers Who Sent Denial Letters Waived Right to Assert Other Coverage Defenses Later.
Eight years ago in
Hoover v. Maxum Indemnity Co., 730 S.E.2d 413 (Ga. 2012), Georgia’s Supreme Court cautioned insurers against the common practice of denying coverage on one ground at the outset of a claim’s investigation, and later amending or supplementing that coverage denial to assert new coverage defenses if the initial reasons for denying coverage fail. Under
Hoover, when an insurer responds to a Georgia policyholder’s claim notification, it has three options: (1) confirm coverage for the claim; (2) defend the claim under a reservation of rights to deny coverage later after a claim investigation; or (3) deny the claim outright.