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...
Judicial and Legislative Developments Threaten Indirect Canadian Acquisitions
Originally published in Tax Notes International, this article examines new obstacles to the recovery by foreign parties of funds that were invested to indirectly acquire, through foreign companies, Canadian targets, raised by the recent decision in Univar and related proposed amendments to certain surplus stripping rules.
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...