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More on FATCA and more to come: the Internal Revenue Service and Treasury Department release proposed regulations
- McCarthy Tétrault LLP
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- Canada, USA
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- April 2 2012
In 2010, the United States amended the Internal Revenue Code of 1986 to add provisions relating to foreign account tax compliance (FATCA
US LLCs may claim refunds in certain circumstances
- McCarthy Tétrault LLP
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- Canada, USA
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- November 3 2010
The Canada Revenue Agency (CRA) recently announced that it will accept claims for treaty benefits by US limited liability companies (LLCs) in certain circumstances
US LLCs limited opportunity?
- McCarthy Tétrault LLP
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- Canada, USA
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- April 26 2010
The April 8, 2010 decision of the Tax Court of Canada in TD Securities (USA) LLC v. R. (2008-2314(IT)G) has reversed a long-standing position of the Canada Revenue Agency (CRA) that US limited liability companies (LLCs) are not entitled to the benefits of the Canada-US Income Tax Convention (Treaty) before the recent amendments made in the Fifth Protocol to the Treaty
Canada-US tax treaty: important CRA guidance on scope of Article IV(7)(b)
- McCarthy Tétrault LLP
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- Canada, USA
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- December 14 2009
The Canada Revenue Agency (CRA) has recently provided administrative guidance on how it intends to apply the so-called "hybrid entity rules" of the Canada-US Tax Convention (Canada-US Treaty
Planning for the entry into force of treaty changes affecting hybrid entities on January 1, 2010
- McCarthy Tétrault LLP
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- Canada, USA
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- September 30 2009
The Fifth Protocol to the Canada-US Tax Convention, 1980 (Canada-US Treaty) introduced important changes of interest to US multinational enterprises with hybrid entities, such as unlimited liability companies (ULCs) and limited liability companies (LLCs), in their cross-border structures
Article V(9) of the Canada-US Tax Convention, 1980
- McCarthy Tétrault LLP
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- Canada, USA
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- May 27 2009
The fifth protocol to the Canada-US Tax Convention, 1980 (the "Treaty") revised Article V(9) and deleted Article XIV
Effective dates of the Fifth Protocol to the Canada-US Income Tax Convention
- McCarthy Tétrault LLP
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- Canada, USA
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- February 23 2009
On December 15, 2008, the Fifth Protocol to the Canada - US Income Tax Convention (Treaty) came into force
The Fifth Protocol to the Canada-US Tax Convention (1980) - relief comes at a cost
- McCarthy Tétrault LLP
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- Canada, USA
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- September 24 2007
On Friday, September 21, 2007, Jim Flaherty, Canada’s Finance Minister, and US Treasury Secretary Henry Paulson Jr., signed the Fifth Protocol (the "Protocol") to the Canada-U.S. Tax Convention (1980) (the "Convention"
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- Jurisdiction - USA
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- Workarea - Corporate Tax
- Firm Name - McCarthy Tétrault LLP
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