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Searching Content indexed under Corporate/Commercial Law by Moodys Gartner Tax Law LLP ordered by Published Date Descending.
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1
Surprise! Foreign Affiliate Dumping Rules Coming To A Private Business Near You
The Foreign Affiliate Dumping ("FAD") rules, contained in section 212.3 of the Income Tax Act (the "Act"), are 10 pages of the Act that many Canadian advisors ...
Canada
1 Apr 2019
2
IRS Regulations Clarify GILTI Tax Relief To US Individual Shareholders With The Sec. 962 Election
One of the many goals of US tax reform implemented by the Tax Cuts and Jobs Act of 2017 ("The Act") was to incentivize large multi-national enterprises that were perceived to be storing profits
United States
21 Mar 2019
3
New Canadian Beneficial Ownership Reporting Requirements Affecting Certain Corporations May Soon Become Law
The Canadian federal government recently introduced Bill C-86, Budget Implementation Act, 2018, No. 2 (Bill C-86) (the "Bill").
Canada
5 Dec 2018
4
Renouncing US Citizenship Or Giving Up A Green Card In The Gulf: Why And How To Consider It
US citizenship or permanent resident status allows access to the largest economy in the world.
United States
24 Oct 2018
5
Reporting Australian Superannuation Funds As Foreign Trusts For Tax Purposes
Current US tax laws do not provide any definitive guidance on the US tax classification and treatment of hybrid foreign retirement plans such as an Australian Superannuation Fund
Australia
9 Oct 2018
6
Canada's Tax Proposals Read Like A Class-Warfare Manifesto Against Private Businesses
On July 18, the Department of Finance released a blockbuster package of proposed tax law changes aimed at private corporations and their shareholders.
Canada
6 Sep 2018
7
Trust Reporting Rules – Draft Legislation Released
As part of draft legislation released on July 27, 2018, the Department of Finance moved forward with new trust reporting rules that were announced in the 2018 Federal budget.
Canada
14 Aug 2018
8
The 2018 Federal Budget And The Passive Investment Proposal Climbdown
On February 27, 2018, the federal government released its annual "budget." This summary focuses only on the tax measures as it relates to private clients and our related commentary.
Canada
1 Mar 2018
9
The US "Transition Tax" For 2017: More Sad News For Many US Citizens Residing Abroad
Transitions come in all different types, some good, some bad, and some just strange.
Canada
14 Feb 2018
10
Income Splitting: Is It Time To Re-Visit A 1966 Canadian Tax Reform Idea?
On July 18, 2017, a blockbuster package of proposed tax law changes (the "proposals") aimed at private corporations and their shareholders, was released by the Department of Finance.
Canada
10 Aug 2017
11
Alberta Investor Tax Credit Program – Even More Bad News
On January 17, 2017, I published a blog about the new Alberta Investor Tax Credit program. For those of you who read my original blog, you'll know that I was and remain very critical of the new program.
Canada
10 Feb 2017
12
Canadians Beware… Do Accidental US Tax Inversions Apply To You?
Phaedrus, the ancient Athenian aristocrat associated with the philosopher Socrates, was famous for the following quote: "Things are not always as they seem; the first appearance deceives many."
Canada
16 Nov 2016
13
CRA Confirms US LLLPs And LLPs Are Indeed Corporations
At the International Fiscal Association conference held in Montréal on May 26, 2016, the CRA orally announced its conclusion that US LLLPs and US LLPs would be classified as corporations for Canadian tax purposes.
Canada
1 Jun 2016
14
United States Limited Liability Limited Partnerships – Are You Ready For The Canada Revenue Agency's New Hybrid Creation?
Canadians who thought they had invested in a partnership when they invested in a US Limited Liability Limited Partnership may be surprised in the coming weeks to find they actually own a "hybrid entity".
Canada
26 Apr 2016
15
New Legislative Proposals For Trusts – Dealing With The Subsection 104(13.4) Problem
On Nov. 16, 2015, I wrote about the ongoing saga regarding subsection 104(13.4) and some good news that was released by the Department of Finance.
Canada
18 Jan 2016
16
Good News Update From The Department Of Finance Regarding Subsection 104(13.4)
Today, I'm pleased to share with you a letter that the Department of Finance just released to the Joint Committee, STEP, and CALU.
Canada
17 Nov 2015
17
Donation Of Private Corporation Shares And Real Estate – New Canadian Legislative Proposals Released
A number of years ago, the government introduced legislation that exempts from taxation realized capital gains when publicly traded securities are gifted directly to registered charities.
Canada
27 Aug 2015
18
Planning Using Principal Residence Trusts For Immigrants To Canada
As many of our readers know, the Canadian Income Tax Act (the "Act") provides for an unlimited exemption from the imposition of Canadian income tax on the gains resulting from a disposition of a "principal residence".
Canada
10 Jul 2015
19
The Loss Restriction Event Rules For Trusts Are Broader Than You Think
Loss carryforwards and other tax attributes, such as scientific research and experimental development ("SR & ED") expenditures, investment tax credits ("ITCs"), resource pools, are valuable assets because they can shelter taxes.
Canada
20 Mar 2015
20
Moodys Gartner Tax Law Responds To Accounting Standards Board On Proposed Accounting Treatment Of Redeemable Preferred Shares Issued In Tax Planning Arrangements
Our firm has long believed that accountants and lawyers should work together in the delivery of tax services. Both professions bring different skill sets and perspectives to the table when crafting client solutions.
Canada
16 Jan 2015
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