July 22, 2020 - The U.S. Treasury Department and the IRS have released final regulations (2020 Final Regulations) allowing certain domestic shareholders of a “controlled foreign corporation” (CFC) to elect under a high-tax exception to opt out of the tax imposed on the CFC’s “global intangible low-taxed...
BEPS on Hybrids: A Canadian Perspective
On March 19, 2014, the Organisation for Economic Co-operation and Development (OECD) released two discussion draft papers on hybrid mismatch arrangements in response to action 2 of the July 2013 action plan on base erosion and profit shifting (BEPS).
June 30, 2020 - The COVID-19 pandemic has resulted in the imposition of safety measures by governments around the world, including that in Canada, to protect the health of their citizens. Similarly, businesses have imposed safety measures to protect their employees. These measures include restrictions on...