Nov. 19, 2020 - In a recent decision, 1 the Court of Québec permanently stayed the prosecution of tax fraud charges made against a corporation and two related individuals after finding "serious, multiple and systemic" 2 violations of constitutional rights. The Court held that the violations revealed "a..."
Fund Management Fee Waivers Under Attack
In this article published in the International Tax Journal, Davies partners Peter Glicklich and Heath Martin examine the proposed regulations issued by the IRS concerning disguised payments for services between partners and partnerships. The regulations are aimed at curtailing the practice of investment fund managers using management fee waivers to convert ordinary income into capital gains. The authors explore the details of the proposed regulations, including the six factors to be considered in determining whether a transaction constitutes a payment for services, as well as their likely impact, both domestically and in a cross-border context.
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...