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...
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.
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...