5 août 2020 - Traduction en cours. 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...
Canada Intent on Stoppin’ the Shoppin’ and More
Disponible en anglais seulement.
Canada’s federal budget for 2014 proposed a rule intended to curtail treaty-shopping: the practice of structuring multinational businesses to take advantage of more favourable tax treaties available in certain jurisdictions. This article presents a number of scenarios to describe how application of this proposed rule would play out in differing circumstances, exposing potential problems that might ultimately discourage foreign investment.
22 juil. 2020 - Traduction en cours. 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...