Canada Intent on Stoppin’ the Shoppin’ and More

Auteur : Michael N. Kandev

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.

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IRS Finalizes High-Tax Exception to GILTI

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...