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...
Upstream Loans and Dispositions of Foreign Affiliate Shares
This article summarizes the upstream loan rules, and explores the impact of the upstream loan rules in several situations involving dispositions of the shares of the creditor foreign affiliate. In general, under the current rules anomalous results can be avoided with certainty only by causing the parent Canadian company to actually repay its outstanding upstream loans borrowed from any creditor foreign affiliates. This may not always be possible or practical. The repayment requirement is arguably too strict and warrants reconsideration.
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...