Jan. 31, 2025 - First published by the Canadian Tax Foundation in (2024) 72:4 Canadian Tax Journal. Treaty Provides Unique Benefits To Canadians Migrating To The United States Canadians who emigrate to the United States or elsewhere face many decisions and considerations...
In the News
Dealmakers adapt to U.S. tax-inversion restrictions – Lexpert
In a Lexpert article exploring how advance knowledge of the U.S. Treasury Department’s anti-inversion regulations has lessened their impact, Davies partner Hillel Rosen discusses the M&A boom in life sciences. “We’re reading about inversion, but the real story is that M&A is the new R&D,” says Hillel. “It incorporates the notion that you can be a pharma company without spending a dollar in research.”
Related
Federal Court of Appeal Confirms CRA Can Collect Arrears Interest Despite Absence of a Tax Debt
Dec. 04, 2024 - The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia’s (BNS) appeal and upheld the Canada Revenue Agency’s (CRA) practice of charging arrears interest on a non-existent tax debt where audit adjustments increase taxable income that is offset by the carryback of a loss...
