Aug. 10, 2020 - The federal government passed legislation on July 27, 2020, extending the Canada Emergency Wage Subsidy (CEWS) and significantly broadening its reach. In this guide, we provide a comprehensive review and analysis of the CEWS program, including details of the latest updates and key considerations...
Foreign Banks and Canada’s CFC System
Originally published in Tax Notes International, this article examines the Tax Court of Canada’s CIT judgment, as well as two pending companion cases, and sheds light on how the simple notion underlying controlled foreign corporation attribution rules— that CFCs’ undistributed passive income should be taxed as earned — can evolve into complex, mechanical, and sometimes convoluted rules.
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...