Oct. 02, 2020 - Bill 42, An Act to give effect to fiscal measures announced in the Budget Speech delivered on 21 March 2019 and to various other measures was assented to on September 24, 2020, bringing into force the new rules respecting the disclosure of nominee contracts to Revenu Québec (RQ ). The...
Canada Intent on Stoppin’ the Shoppin’ and More
Canada’s federal budget for 2014 proposed a rule intended to curtail treaty-shopping: the practice of structuring multinational businesses to take advantage of more favourable tax treaties available in certain jurisdictions. This article presents a number of scenarios to describe how application of this proposed rule would play out in differing circumstances, exposing potential problems that might ultimately discourage foreign investment.
Sept. 29, 2020 - The U.S. Internal Revenue Service (IRS) published proposed regulations (the Proposed Regulations) on August 14, 2020, providing much-needed guidance on the implementation of the carried interest rules under Section 1061. 1 These rules will be of great interest to investment fund managers as well...