Jan. 30, 2020 - In our annual Tax Review and Outlook report, we look back at significant developments that shaped the Canadian and U.S. tax landscapes in 2019 and offer our predictions on what to expect in the year ahead. Key Canadian Developments in 2019 Proposed changes to the employee stock option rules...
Metal Streams in Foreign Affiliates
Originally published in the CCH International Tax Newsletter, this article considers the principal features of the typical metal stream transaction that are relevant from a tax perspective. The focus is on the common situation of a Canadian parent company owning a non-Canadian mining property through a foreign affiliate, and selling a metal stream based on the future production from that foreign affiliate’s mining property.
Jan. 30, 2020 - Review of U.S. Tax Developments in 2019 In 2019, the U.S. tax world continued to be primarily concerned with developing guidance under the monumental Tax Cuts and Jobs Act (TCJA), which was enacted at the end of 2017. Major regulatory projects were proposed beginning in 2018,...