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...
June 2014 Election Deadlines for Retroactive Application of New Foreign Affiliate Reorganization Rules
This article examines the new foreign affiliate reorganization provisions and key elections affecting Canadian corporations with foreign affiliates. It may now be possible for taxpayers to clarify, proactively confirm, or even change the intended tax consequences of historic transactions that closed after December 20, 2002.
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...