Tax

For multi-national organization, navigating intricacies of the US and international tax frameworks traverses beyond routine compliance, calling for a proactive, strategic approach. Our Caribbean and Bermuda professionals deliver a comprehensive suite of tax advisory and services to investment management firms and hedge funds ranging from managing technical insurance tax regimes to delivering actionable insights, ensuring rigorous compliance that drives overall financial performance.

• Insurance taxation (Subchapter L): our team of qualified professionals help optimize complex requirements—including reserve deductions, deferred acquisition costs (DAC), policyholder dividends, and premium-related adjustments—to align seamlessly with your broader business objectives.
• Federal Corporate Income Tax: we provide comprehensive compliance and proactive tax planning support under U.S. corporate tax frameworks. Our sophisticated strategies for Net Operating Loss (NOL) utilization, interest deductibility limitations (IRC §163(j)), and complex timing differences help maximize capital efficiency.
• ASC 740 Tax Accounting: we provide comprehensive support in preparation and review of income tax provisions under U.S. GAAP. Our professionals efficiently deliver tax rate (ETR) analysis, accurate valuation allowance assessments, and audit-ready disclosures.
• Cross-Border & International Tax: we deliver robust inbound and outbound tax structures designed to withstand global scrutiny. Our specialized advisory on Controlled Foreign Corporation (CFC) considerations, transfer pricing alignment, and seamless coordination with non-U.S. operating entities ensures your global tax strategies remain compliant and optimized in a time-efficient manner.
• Tax Controversy & Risk Management: We help you effectively mitigate enterprise risk through comprehensive management of uncertain tax positions (FIN 48), audit readiness, and strategic guidance during IRS examinations.

On 27 December 2023, the Government of Bermuda enacted the Corporate Income Tax Act. The Act introduces a 15% Corporate Income Tax (CIT) on Bermuda businesses that are part of Multinational Enterprise (MNE) groups with annual revenue of EUR750 million or more. Since commencement of the CIT regime on 1 January, 2025, the Bermuda CIT rules incorporate key foundational definitions from the Organization for Economic Co-operation and Development (“OECD”) Pillar Two and global anti-base erosion (“GloBE”) model rules to remain aligned as far as practicable with the GloBE rules.

• Scoping analysis: We provide advisory support covering overview of Bermuda tax legislation and regulatory guidance as applied to specific fact patterns, assessment of whether an entity falls within the scope of the Bermuda CIT regime, evaluation of relevant elections and tax planning opportunities, and a summary of key deadlines and other considerations necessary to maintain compliance with the Bermuda CIT framework.
• Substance based tax credit: This credit applies specifically to insurance companies with 20 or more Bermuda based employees. We advise eligible insurers on the application of Bermuda’s payroll linked tax credits, including circumstances where the group is not otherwise subject to Bermuda Corporate Income Tax (CIT). Our services include eligibility assessments, calculations based on job and expense-based components, related accounting considerations, and preparation of required tax filings, with credits available to offset CIT or payroll tax or be claimed as a cash refund.
• Financial reporting: We provide income tax provision support for Bermuda CIT, including quarterly, current and deferred tax calculations, identification of tax sensitive accounts driving temporary and permanent differences, and reconciliation of accounting and tax bases (such as GAAP to STAT deferred taxes). Our services also cover valuation allowance assessments, other technical tax accounting matters, and preparation of Bermuda CIT related financial statement disclosures under the applicable accounting standards.
• Compliance: We support Bermuda CIT compliance for organizations by assisting in data collation and taxable income calculations, analysing required elections prior to filing, and supporting with estimated tax payments and interim filings. Our services also include preparation and submission of the Bermuda CIT return, with seamless integration into Deloitte’s Pillar Two Agent to enable efficient, globally coordinated compliance delivery.

Rules per The Organization for Economic Co-operation and Development (OECD) Pillar Two model requires in-scope multinational enterprises to pay a minimum of 15% level of tax on income arising in each of the jurisdictions they operate in. This places the enterprises impacted by OECD Pillar Two taxes in a position where they will require an understanding of the new rules, reporting requirements to be able to coordinate tax, finance, IT and legal inputs. The processes involved in turn requires access to right data, eye for detail, technology evaluation, preparing training resources and more. 

Our qualified professionals help organizations not only assess the impact on current and future business plans but also deliver targeted technical assistance to assess global impact and deliver compliance oversight.

As regulatory requirements evolve around improving international tax transparency and combatting tax avoidance, our team of experienced professionals support organizations in assessing the impact emerging from the resulting obligations. Our range of services include:

• Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) services
• Country-by-Country Reporting (CbCR) notifications and filings
• Economic Substance (ES) assessments and reporting 
• Other Base Erosion and Profit Shifting (BEPS) services

As Automatic Exchange of Information (AEOI) regimes continue to expand, organizations face various challenges such as increasing compliance burden, risks of misclassification, and incomplete reporting. We work with organizations to simplify the processes and implement a practical, end-to-end AEOI approach which connects entity classification, documentation and more.

Our support extends beyond classificiation to cover FATCA/CRS reporting, and Country-by-Country Reporting (CbCR), as well as developing and enhancing AEOI policies and procedures to improve consistency, operational readiness, and auditability.

We bring a tailored approach to develop innovative solutions for solving our clients' biggest challenges in operational finance, HR & payroll, and tax compliance operations.

Our team of experienced professionals provide practical support in enhancing management, and control of operations through both in-house and external resources as well as flexible delivery models, digital solutions, staff augmentation, co-sourcing, and other services, which include: 

• Tax & Statutory Compliance: our tailored services support clients at every stage from preparing financial statements and disclosures to managing compliances under local GAAP, IFRS, and US-GAAP frameworks, including ledger conversions and accounts reconciliation. 
• Financial and Accounting Operations (Finance and Tax Operate): our innovative ecosystems are designed to meet the clients' needs at every stage, supporting in outsourcing, co-sourcing, staff augmentation and digital advancement. 
• HR & Payroll Advisory (Operate): we cater to every aspect of payroll and social benefits with a focus on compliance, regulatory and employment tax among others.