Aug. 05, 2020 - The IRS recently released long-awaited final regulations (Final Regulations) on the limitation on the deductibility of interest expenses under section 163(j), along with new proposed regulations (New Proposed Regulations) that address a variety of highly technical issues that are not covered by...
Canadian Tax Highlights: Québec Ombudsman Lambastes Revenu Québec
The public protector (or ombudsman) is appointed by the Québec National Assembly with the mandate to “intervene . . . whenever [s]he has reasonable cause to believe that a person or group of persons has suffered or may very likely suffer prejudice as the result of an act or omission of a public body.” The public protector enjoys extensive investigatory powers, and her jurisdiction extends to Revenu Québec. The public protector regularly intervenes in audits, collection disputes, file processing, and other disputes with Revenu Québec after receiving complaints from taxpayers. The 2013-14 annual report, tabled on September 18, 2014, made headlines because of its searing indictment of a wide range of audit, collection, and customer service practices in which Revenu Québec officials “use, or in some cases, misuse, conferred powers to claim amounts that threaten the viability of businesses, without properly supporting their conclusions.” This article summarizes the report’s comments on Revenu Québec.
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...