Latest news with #Cayman
Forbes
2 days ago
- Business
- Forbes
New Self-Employment Tax Risks For U.S. Investors In Global Funds
A new Tax Court ruling is a warning for U.S. limited partners in global funds, imposing new ... More self-employment (SECA) tax risks. U.S. limited partners in foreign funds like Cayman or Luxembourg partnerships must ensure passive roles to avoid costly SECA tax liabilities. The U.S. Tax Court decided Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) in May 2025 leaving financial, tax and legal advisors concerned. The court upended assumptions about the self-employment tax exemption for limited partners in hedge funds, and by analogy to venture capital, and private equity partnerships both in the U.S. and abroad. U.S. citizens and green card holders who are limited partners in hedge funds or similar businesses, including those in foreign countries, should understand the effects of this decision. The case signals a shift away from a state or local law definition of a 'limited partner' toward a more comprehensive evaluation of the partner's actual role to determine if the 'limited partner' exclusion from Self-Employment Contributions Act taxes should apply. The Soroban court applied a 'functional analysis test' to determine whether limited partners' distributive share of partnership income is subject to SECA taxes. The decision has far-reaching SECA implications for how limited partners will structure their roles and manage their tax obligations. This article explores the Soroban ruling, what it means for U.S. limited partners, especially for those working with hedge funds or other businesses abroad that use a limited partnership structure. First, it is helpful to understand generally why funds often use a limited partnership vehicle. A limited partnership for U.S. purposes is comprised of both general and limited partners. General partners manage the fund and have unlimited liability. Limited partners contribute capital, and their liability is limited to their investment. The limited partnership structure is tax transparent for U.S. tax purposes, meaning it provides pass-through taxation of income, credits and deductions to its partners. The partnership entity itself is not subject to U.S. income tax, and the partners report their distributive shares on their individual U.S. tax returns. The structure also provides significant flexibility in governance. For all these reasons, the limited partnership is often ideal for private funds. Self-employment income is taxed at a rate of 15.3% (12.4% for Social Security and 2.9% for Medicare). A SECA exclusion exists under Internal Revenue Code Section 1402(a)(13) for a limited partner's distributive share of partnership income. The Tax Court rejected the notion that state law classifications of limited partners should be determinative for purposes of this exclusion. Instead, it applied a functional analysis test to Soroban's limited partners and concluded that these partners were 'limited in name only.' As such, the limited partners' distributive share did not qualify for the SECA exclusion. The court carefully examined the activities of the limited partners and found they were heavily involved in generating the partnership's income by overseeing day-to-day management, working full-time for the business, and that marketing material listed them as essential to the success of the partnership. In addition, the capital contributions made by the limited partners were viewed as insignificant when compared to the fees Soroban charged. This comparison suggested that the limited partner's distributive share was not a passive return on investment but rather compensation for active participation. The label 'limited partner' alone, is not enough to guarantee the SECA exclusion. Instead, the functional analysis test requires a thorough analysis of the facts and a careful examination of the partner's role in the enterprise. The factors include how integral the partner is in generating revenue, the degree of participation in the business, whether the partner is working full-time in the business, whether marketing materials indicate the partner plays a key role and whether the partner's capital investments truly reflect a passive investment. For U.S. limited partners, particularly those in hedge funds or other investment vehicles, the Soroban holding invites the IRS and courts to closely scrutinize the actual activities of limited partners to determine SECA liability. While the Soroban case focused on a U.S. hedge fund, its principles can apply to any partnership structure in which U.S. citizens or green card holders are limited partners. The holding can apply to a vast range of industries operating globally where U.S. partners are contributing expertise and management. Private equity firms, venture capital funds, and other businesses often use a limited partnership structure. A limited partner in an overseas real estate partnership or tech startup fund could face scrutiny if the role involves active management or income generation. Only truly passive investors are meant to benefit from the SECA exclusion and while local law will be important in the analysis, the IRS will be looking beyond any local law label of 'limited partner' to scrutinize eligibility. Various jurisdictions have limited partnership structures closely resembling the U.S. model. The most popular jurisdictions having limited liability for limited partners as well as generally having flow-through tax treatment include the Cayman Islands, British Virgin Islands, Luxembourg, Hong Kong and Ireland. While these jurisdictions appeal to global funds because of their tax and regulatory regimes which parallel the U.S. in important respects, limited partners should be ready to consider a heightened compliance burden given the holding in Soroban. Adding to the additional possible tax burden, the U.S. limited partner abroad will be unhappy to learn that self-employment income subject to SECA tax is not reduced by the foreign earned income exclusion. U.S. limited partners should reassess their involvement in the partnership to make sure they qualify as passive investors entitled to the SECA exclusion. This may mean a significant reduction of day-to-day management responsibilities or restructuring their roles to emphasize capital investment over active participation. For U.S. limited partners in foreign funds, the statute of limitations for SECA tax assessments is generally three years from the due date or actual filing date of the income tax return, whichever is later. However, the statute of limitations for tax matters can be extended several years and even indefinitely, depending on the facts. Crucially, if a U.S. partner fails to file a required foreign information return, such as Form 8938 (Statement of Specified Foreign Financial Assets) or Form 8865 (Return of U.S. Persons With Respect to Certain Foreign Partnerships), the statute of limitations does not start for the entire tax return. This gives the IRS the ability to assess SECA tax at any time in the future. U.S. limited partners should be proactive and planning for a possible IRS challenge to a claimed exclusion from SECA. U.S. limited partners should first consult an experienced tax advisor to assess their involvement in the fund and optimize tax outcomes. Next, meticulously document management roles, time commitments, and public representation to ensure compliance with IRS scrutiny and minimize the risk of tax exposure. Partnership agreements should be examined. If feasible, partnership agreements may need to be amended to clarify the role of limited partners as passive investors, emphasizing capital contributions over operational involvement. Limited partners who blur the line between passive investment and active management could find a surprising increase in their U.S. tax liability with their distributive shares subject to SECA taxes. The Soroban case may be appealed, and staying informed on this topic is critical. Investors should be looking out for any future IRS guidance or legislation that might refine the functional analysis test. I help with tax matters around the globe. Reach me at vljeker@ Visit my US tax blog
Yahoo
5 days ago
- Business
- Yahoo
ZTO Express (Cayman)'s (NYSE:ZTO) Returns On Capital Are Heading Higher
What are the early trends we should look for to identify a stock that could multiply in value over the long term? One common approach is to try and find a company with returns on capital employed (ROCE) that are increasing, in conjunction with a growing amount of capital employed. If you see this, it typically means it's a company with a great business model and plenty of profitable reinvestment opportunities. Speaking of which, we noticed some great changes in ZTO Express (Cayman)'s (NYSE:ZTO) returns on capital, so let's have a look. AI is about to change healthcare. These 20 stocks are working on everything from early diagnostics to drug discovery. The best part - they are all under $10bn in marketcap - there is still time to get in early. For those that aren't sure what ROCE is, it measures the amount of pre-tax profits a company can generate from the capital employed in its business. The formula for this calculation on ZTO Express (Cayman) is: Return on Capital Employed = Earnings Before Interest and Tax (EBIT) ÷ (Total Assets - Current Liabilities) 0.19 = CN¥12b ÷ (CN¥93b - CN¥29b) (Based on the trailing twelve months to March 2025). Therefore, ZTO Express (Cayman) has an ROCE of 19%. On its own, that's a standard return, however it's much better than the 13% generated by the Logistics industry. See our latest analysis for ZTO Express (Cayman) In the above chart we have measured ZTO Express (Cayman)'s prior ROCE against its prior performance, but the future is arguably more important. If you're interested, you can view the analysts predictions in our free analyst report for ZTO Express (Cayman) . Investors would be pleased with what's happening at ZTO Express (Cayman). The numbers show that in the last five years, the returns generated on capital employed have grown considerably to 19%. The company is effectively making more money per dollar of capital used, and it's worth noting that the amount of capital has increased too, by 67%. This can indicate that there's plenty of opportunities to invest capital internally and at ever higher rates, a combination that's common among multi-baggers. For the record though, there was a noticeable increase in the company's current liabilities over the period, so we would attribute some of the ROCE growth to that. Essentially the business now has suppliers or short-term creditors funding about 31% of its operations, which isn't ideal. Keep an eye out for future increases because when the ratio of current liabilities to total assets gets particularly high, this can introduce some new risks for the business. All in all, it's terrific to see that ZTO Express (Cayman) is reaping the rewards from prior investments and is growing its capital base. Given the stock has declined 50% in the last five years, this could be a good investment if the valuation and other metrics are also appealing. So researching this company further and determining whether or not these trends will continue seems justified. On the other side of ROCE, we have to consider valuation. That's why we have a that is definitely worth checking out. For those who like to invest in solid companies, check out this free list of companies with solid balance sheets and high returns on equity. Have feedback on this article? Concerned about the content? Get in touch with us directly. Alternatively, email editorial-team (at) article by Simply Wall St is general in nature. We provide commentary based on historical data and analyst forecasts only using an unbiased methodology and our articles are not intended to be financial advice. It does not constitute a recommendation to buy or sell any stock, and does not take account of your objectives, or your financial situation. We aim to bring you long-term focused analysis driven by fundamental data. Note that our analysis may not factor in the latest price-sensitive company announcements or qualitative material. Simply Wall St has no position in any stocks mentioned. Sign in to access your portfolio
Daily Mirror
09-06-2025
- Automotive
- Daily Mirror
9 cars set to be axed in 2025 including two really recognisable vehicles
As manufacturers respond to new regulations, electrification and changing consumer demand, motorists after these models must act swiftly, otherwise they'll be gone for good A number of the UK's much-loved motorcar models will be axed by the end of the year, marking a huge shift in the automotive landscape. While the UK accelerates its transition over to electric vehicles, certain models are being retired to better align with evolving consumer tastes and make way for newer technology. For years, drivers of electric, zero, or low-emission cars were offered huge cash benefits, such as vehicle tax discounts and exemptions from the 'Expensive Car Road Tax'. While many of these incentives have been cut, which you can learn more about here, Brits are still being encouraged to go for cleaner vehicles. As manufacturers prepare for stricter emissions regulations, here are nine cars confirmed to be discontinued by the end of 2025 — if they haven't been canned already — including some of the most recognisable and iconic brands on the road. 1. Lexus LS After 35 years on sale, the ultra-luxury Lexus LS saloon is being discontinued in the UK due to poor sales. Once hailed as a game-changer when it launched in 1990, the LS helped establish Lexus as a serious competitor to European and American luxury brands. The final generation, the LS 500, launched in 2017 and was updated in 2020. Despite a starting price of over £100,000, only 39 hybrid V6 models have been sold since 2020, with just three last year, leading to its demise in the UK market. 2. Mazda2 Mazda confirmed in February 2025 that the Mazda2 supermini, which has been on sale in its most current iteration for a decade — the earliest version was launched in the UK in 2003 — is no longer available to order. Known for its fun driving experience, the petrol and mild-hybrid versions have been replaced by the Mazda2 Hybrid, essentially a rebadged Toyota Yaris. Mazda cited a shift towards electrification and consumer demand for hybrids as reasons for the change, aiming for all their cars to have some form of electrification by 2030. A Mazda spokesperson told Autocar: "As we move towards increased electrification of our cars, the Mazda 2 Hybrid meets consumer demand in the B-segment and is a step in our journey to ensure all our cars have some form of electrification by 2030." 3. Mazda MX-30 Mazda's first and only electric car, the MX-30, is also being discontinued after just four years. Launched in 2021 as an EV or plug-in hybrid, it struggled due to its limited range of just 124 miles and cramped cabin space. The smaller battery was chosen to reduce weight and emissions but caused range anxiety among drivers. While the fully electric MX-30 is being axed, the plug-in hybrid version remains available in the UK. 4. & 5. Porsche Boxster & Cayman Porsche announced that production of the petrol-powered 718 Boxster and Cayman will end in October 2025. These iconic sports cars have no confirmed electric replacements yet, but an electric successor is expected eventually. Sales in Europe ceased in summer 2024 due to new EU cybersecurity rules, though the UK market continues unaffected post-Brexit. Porsche's head of production confirmed the global end of petrol 718 models by October 2025. 6. Nissan GT-R The Nissan GT-R R35, first unveiled in 2007, has been unavailable in the UK for some time. Production ended in Japan in early 2025, marking the loss of its final market. It was discontinued in the UK and Europe in 2022, and in the USA and Canada in 2024. Nissan's financial difficulties could delay or derail plans for a fully electric GT-R successor, making this a significant moment for fans of the iconic "Godzilla" sports car. 7. & 8. Audi A1 & Q2 Audi shocked the market by announcing the end of production for the popular A1 hatchback and Q2 crossover in 2026. Both are among Audi's cheapest and best-selling models, but neither is sold in the US or China. Audi plans no direct successor for the A1, instead focusing on a new entry-level electric vehicle to serve as an alternative to the A3 and Q3, reflecting the brand's shift toward electrification. Audi CEO Gernot Döllner told Autocar that the manufacturer 'will end production of the A1 and Q2' in 2026, and that there 'definitely will be no successor for the A1'. He added: "We will also see the car that will enter production next year in Ingolstadt [where Audi is based], which will be our entry BEV in the A-segment". 9. Ford Focus ST After 23 years, the Ford Focus ST is being taken off sale in the UK, with production ending in November 2025. The ST could still be ordered as recently as April, but has now disappeared from dealer price lists. Ford said in a statement: "There are no new factory orders available for the Focus ST at the moment, but there are around 170 built and unsold currently available within the UK dealer network. This includes 30 of the special ST Edition variant in Azura Blue." The retirement of these nine models signals a much larger shift in the motoring world. As manufacturers respond to new regulations, electrification, and changing consumer demand, fans still after these models need to act fast, otherwise they'll be gone forever.
Yahoo
30-05-2025
- Entertainment
- Yahoo
Caymanian Queen Jada Ramoon Ready to Fly the Cayman Islands Flag at Miss World Final
Miss World Cayman Islands, Jada Ramoon, competes in the 72nd Miss World pageant tomorrow (31st May) in Telangana, India. George Town, Cayman Islands, May 30, 2025 (GLOBE NEWSWIRE) -- Jada Ramoon, Miss World Cayman Islands, is preparing to take centre stage tomorrow, Saturday 31st May, as she competes in the 72nd Miss World pageant in Telangana, India. The pageant's red carpet will commence at 7 a.m. Cayman time, with the main event beginning at 8 a.m, which can be seen on TVJ, channel 30 on Logic TV. Representing the Cayman Islands with grace and determination, Jada has taken part in a series of preliminary challenges over recent weeks, including Talent, Head-to-Head, Sports, Multimedia and Beauty with a Purpose. She secured placements in both the Talent and Head-to-Head competitions—a remarkable achievement on the world stage. Reflecting on her journey thus far, Jada shared: "I'm feeling a mixture of nerves and excitement as Saturday draws near. I'm hopeful that I can continue to make history for Cayman. I'm truly grateful for how things have unfolded so far; it's been a humbling and incredible experience. I'm proud to be here, representing the place I love and proudly call home." Beyond the competition, Jada has embraced the opportunity to learn about the vibrant culture of Telangana, bond with her fellow contestants, and share the values and heritage of the Cayman Islands with a global audience. Homecoming: The Cayman Islands public is warmly invited to welcome Jada upon her return. She is scheduled to arrive at Owen Roberts International Airport on Monday, 2nd June at 4:30 p.m. To learn more about Jada's journey and the Miss World competition, please refer to our previous release or follow the official Miss World Cayman Islands channels. About Storytellers: Storytellers is a Cayman Islands based digital PR and news company specialising in strategic communications, media relations, and digital content creation. The company works with global businesses, organisations, and public figures to amplify their stories and connect with audiences across North America, the Caribbean, UAE, Canada, China, and beyond. Media Contact: Publicity Partner Storytellers Qamar Zaman T: 1-345-327-7206 Error in retrieving data Sign in to access your portfolio Error in retrieving data Error in retrieving data Error in retrieving data Error in retrieving data
Auto Express
28-05-2025
- Automotive
- Auto Express
New electric Alpine A110: next-gen sports car to showcase brand's track pedigree
Ready for the first two-seat, all-electric coupe with the 'soul' of French racing brand Alpine? It's coming up fast and promises to be something special to rival Porsche's upcoming electric Cayman and Boxster, a string of Alpine executives told Auto Express at the brand's 70th anniversary party in its hometown of Dieppe. Advertisement - Article continues below Alpine's boss Philippe Krief and Renault Group's irrepressible leader Luca de Meo talked in depth about Alpine's electric replacement for the A110 coupe, revealing a string of technical headlines. The electric coupe will ride on a dedicated sports car platform, has a target weight of 1,450kg (close to a Cayman GT4 RS's), should travel more than 350 miles on a charge, and packs two in-wheel motors that generate 'more than enough power – I can guarantee [it],' vows ex-Ferrari director of engineering Krief. The A110 will be the cornerstone of Renault Group's attempt to take Alpine's track pedigree – racing in Formula 1 and the World Endurance Championship – and turn the brand into a thriving, seven-model premium car maker at the cutting edge of new technology. It's critical that the brand's low-slung, electric SUV – the A390, unveiled at the Dieppe event – is a success to start generating the cash the company will need to invest. Skip advert Advertisement - Article continues below De Meo's vision is to create France's answer to Porsche. '[The A110] is our iconic product, the Porsche 911 of Alpine,' he says. Coincidentally the first A110 coupe – powered by an in-line Renault four-cylinder engine – made its debut in 1963, the same year the 911 was born. While the A390 rides on a painstakingly overhauled version of Renault Group's AmpR-Medium architecture, the coupe will be the first model on the Alpine Performance Platform (APP), and is set to be unveiled at the Paris motor show in October 2026. Advertisement - Article continues below 'Irrationally, we decided to invest in a very modular sports car platform that will underpin the next-generation A110,' explains de Meo. 'The APP is the core of [Alpine]. The priority is to take that platform and develop three or four models, then we'll see what happens.' De Meo told Auto Express that APP is a dedicated sports car platform, made from extruded aluminium sections. It will be manufactured in the Dieppe factory, where workers are used to crafting the lightweight alloy. The material is critical for paring back weight. 'We think we can do an electric car that is lighter than a comparable combustion-engine car,' says de Meo. 'That will change everything. We've invested in the electronic engine architecture, putting the engines in the wheel, [which] lowers the car's centre of gravity.' Skip advert Advertisement - Article continues below The A110 will finesse the in-wheel motor technology powering the Frankenstein's monster version of the Renault 5, the Turbo 3E. Alpine's engineers have converted this outrageous, £135,000 superhatch to rear-wheel drive, with rotors attached to the wheels to spin them. That negates the need for reduction gears and half-shafts, saving weight, and gives huge opportunity to manage torque delivery to individual wheels. While the Turbo 3E will be a drift machine, the new A110 will be set up to carve through corners. Advertisement - Article continues below 'There will be two motors [on the rear],' says Philippe Krief. 'We'll also have an all-wheel-drive version with two [rear] and one different [front motor] – smaller, lighter.' And how much combined power will there be, in excess of 500 horsepower? 'A lot!' he says. 'And we are thinking of evolution also (to give a range of outputs and models). There will be enough power, I can guarantee!' The motors will be fed by 'very high energy density' batteries and an 800-volt electrical architecture, boosting charging capability and enabling thinner wiring and componentry to again reduce weight. 'In terms of motors, you optimise them. Integrate all the functions – motor, transmission, inverter, the DC/DC charger – everything in one box. Then in terms of vehicle integration, you fight for every millimeter you can reduce, every kilo on each single part. I'm not saying that it's easy!' vows Krief. Skip advert Advertisement - Article continues below 'The weight target of the new A110 is below the best combustion car, a Porsche [718 Cayman],' he confirms. '[It's] 1.45 [tonnes] to be precise.' Today's entry-level A110 is extremely petite, stretching to just 4,181mm long and weighing 1,102kg. That means a relatively modest 249bhp four-cylinder engine can fire the coupe from standstill to 62mph in 4.5 seconds. Krief admits the electric coupe will have a slightly bigger frame, but positioning the batteries will be key to keeping the coupe's height below 1.3 metres – comparable with the current car's roofline. 'We cannot put the battery in the floor because the car will be too high,' Krief tells Auto Express. 'So we will put the battery elsewhere and we've found some really nice battery installation. 'A big stack is [cost] efficient and if I put my battery in two packs, it will be less efficient. But you definitely could do more than one installation. This is something we can afford because we don't want to trade off on the project: the new A110 has to be a real A110.' Advertisement - Article continues below One stack could be placed behind the rear seats in the classic mid-engined position, with the in-wheel motor design freeing up some space. More cells could be located up front but behind the axle line. Weight distribution will dictate the positioning: the A390 five-seat 'fastback' has a 49:51 front:rear bias, although its single battery pack lies in the floor. Skip advert Advertisement - Article continues below Krief reckons the electric A110 should be good for a range of 600km (373 miles) – customers won't accept the 'easy' trade-off of a small battery compromising usability. And he believes the switch to electric, with its precise tunability and instant response, will make for an agile-feeling sports car. 'If you give the car a sense of the benefit of [being] electric – quickness in steering and responding, quickness in braking, quickness in recovering from understeer, oversteer – then you have the [lightweight] feeling. In this, electric has a huge advantage, because in terms of response an electric machine is 10 times faster than [a mechanical one].' Alpine is also experimenting with a sound symposer on the A390, with lower, bassier frequencies in Sport than in regular Daily mode. The soundtrack is generated in real time, based on throttle position, motor speed and other variables, and this thinking is sure to influence the A110 driving experience. The electric A110 will be true to its forebears in being instantly recognisable, in the same way Porsche design nurtures the 911's look. 'For premium brands, you need a certain consistency, a family feeling,' says group CEO de Meo. 'There will always be some fixed points that are characteristic of Alpine so that you can recognise the products from 200 metres away.' Advertisement - Article continues below Skip advert Advertisement - Article continues below The new A390 fastback displays the common threads of Alpine design, says group vice president Laurens van den Acker. 'You have a pointed front end, with Alpine written in the front and the double-headlight signature. You have the body side line that drops down and the very nice rear window.' Shaped like a helmet's vizor, it unites the A110 and A390. 'But we want to give every car its personality,' van den Acker tells us. 'The A110 will be replaced. If you want the pure DNA of the brand, it's always available in the A110: it's the roots on which we're growing a tree. The A110 will be very recognisable, but in terms of proportions and surfacing, it will evolve – for the better I'd say.' The APP sports car platform allows for bigger wheels to boost the stance. 'And it's versatile because you cannot make money with one sports car. Because it's extruded aluminum, it's relatively easy to change the wheel base or width. And that helps pull different vehicles off it,' says the design director. Alpine boss Krief predicts APP will underpin the two-seat coupe and a roadster version, plus 2+2-seater models. It's an ambitious plan, which should add a 1,000bhp hybrid supercar and potentially a bigger SUV on top, if Alpine eventually decides to attack the US market. But why will it work, given that French car makers have typically failed to crack the premium market? Luca de Meo believes the electric transition is a great leveller. 'More or less, we are on a par with the others. Everybody's learning, everybody's investing in battery technology and e-motors. It's not that we have a 100-year gap to close so maybe it's an opportunity for us. 'In the first generation, electric cars have been, in the main, appliances like washing machines – kind of ugly and unemotional. Maybe we can prove that electric car technology can actually be fun, that we can put in a soul. Alpine's original position was doing more with less, the use of materials, of lightness instead of a big thing with big batteries. That's the window I see again.' Tell us what you love (and hate) about your car. Take the Driver Power survey now and you could win a £1,000 John Lewis voucher Find a car with the experts It's only a matter of time before Jaguar Land Rover builds a factory in the USA It's only a matter of time before Jaguar Land Rover builds a factory in the USA Mike Rutherford thinks Jaguar's 'Reimagine' strategy will result in the company exploring further opportunities in the USA Slow death of the manual car revealed in exclusive new data Slow death of the manual car revealed in exclusive new data There are now very few manual cars available to buy, a trend that's been exacerbated by the rise of EVs Car Deal of the Day: Nissan's X-Trail is a do-it-all seven-seat hybrid SUV for only £235 a month Car Deal of the Day: Nissan's X-Trail is a do-it-all seven-seat hybrid SUV for only £235 a month If the Qashqai is too small for you, then the larger X-Trail is a fine alternative. It's our Deal of the Day for 25 May
