May 28, 2020 - The U.S. Treasury Department has issued regulations for debt-equity recharacterization under section 385 of the Internal Revenue Code (the Final Regulations) that finalize without substantive change proposed regulations promulgated in October 2016 (the 2016 Proposed Regulations). Section 385...
The Univar Appeal: A Pyrrhic Victory For Indirect Acquisitions in Canada
In this article published in Tax Notes International, Davies partner Nathan Boidman reviews the decision by the Federal Court of Appeal in Univar Holdco Canada ULC v. The Queen, particularly in the context of the 2016 Income Tax Act amendments concerning surplus stripping rules and the general anti-avoidance rule on foreign parties’ recovery of funds invested in indirect acquisitions of Canadian targets.
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May 27, 2020 - As part of the federal government’s response to the COVID-19 pandemic, the Department of Finance recently published a draft legislative proposal, the Time Limits and Other Periods Act (COVID-19) (Proposal), that, if implemented, would provide for an automatic six-month suspension of...