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...
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.
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...