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...
Interest Deductibility in Canada: The TDL Group Co. Decisions
Originally published in Tax Notes International, this article examines the conclusions reached by both the Tax Court of Canada denying an interest deduction and by the Federal Court of Appeal subsequently allowing the deduction in an effort to identify a more unified theory on the proper approach.
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...