Article

Judicial and Legislative Developments Threaten Indirect Canadian Acquisitions

Author: Nathan Boidman

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.

Download this article.

Key Contacts

Nathan Boidman
Nathan Boidman

Senior Counsel

514.841.6409

Expertise

Related

IRS Releases Final Regulations on Deductibility of Business Interest Expense

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...

IRS Finalizes High-Tax Exception to GILTI

July 22, 2020 - The U.S. Treasury Department and the IRS have released final regulations (2020 Final Regulations) allowing certain domestic shareholders of a “controlled foreign corporation” (CFC) to elect under a high-tax exception to opt out of the tax imposed on the CFC’s “global intangible low-taxed...