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U.S. and multi-national companies engaged in Canadian business operations through controlled Canadian subsidiaries need to stand on guard for possible legislation on interest stripping and other rules
- Fox Rothschild LLP
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- Canada, USA
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- December 6 2012
Many U.S. companies engage in business operations in foreign countries, including Canada, through the use of a controlled or wholly owned subsidiary
New technical interpretation issued by Canada Revenue Agency on stock options will spark debate
- Fox Rothschild LLP
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- Canada, USA
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- November 8 2011
A recent technical interpretation issued by the Canada Revenue Agency, Technical Interpretation 2011-0393411E5, provides that under Article XV of the Canada-U.S. Income Tax Convention, that after 2008, when a U.S. resident employee of a Canadian resident corporation acquires shares of the corporation on the exercise of employee stock options, the Canada Revenue Agency (CRA) would disallow that the income from the taxable amount would qualify for exemption from Canadian income tax under the Canada-U.S. Tax Treaty, even if the employer was not present in Canada for more than 183 days
Canadian investment in U.S.-based private equity funds: preference for the U.S. limited liability company
- Fox Rothschild LLP
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- Canada, USA
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- February 4 2011
Canadians seeking to make investments in US-based private equity funds do face a challenging landscape attributable to the multitude of US taxing authorities, federal, state and local governmental taxing authorities, as well as a somewhat counterintuitive home country tax regime, in reporting their U.S. operations back home in Canada
Canadian Tax Court rules Delaware LLC is U.S. resident for treaty purposes in TD Securities (USA) LLC v. Her Majesty the Queen
- Fox Rothschild LLP
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- Canada, USA
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- April 20 2010
In a detailed and comprehensive review of the US-Canada Income Tax Convention, the recently issued Fifth Protocol, and the OECD Model Treaty and related Commentaries, as well as the domestic tax law treatment of single member limited liability companies, pass through entities and other organization, the Canadian Tax Court, in an opinion written by Patrick Boyle, on April 8, 2010, concluded that implicit in the clear intention of the OECD countries, including Canada and the US, that treaty benefits be enjoyed by TD LLC in the present circumstances, and given the context of the Canadian and US tax régimes and the text of the US Treaty, TD LLC must be considered to be a resident of the US for purposes of the US Treaty otherwise the treaty could not apply
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- Jurisdiction - USA
- Jurisdiction - Canada
- Author - Jerald David August