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...
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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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...