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CRA confirms tax treatment of US downstream absorptive merger

Thorsteinssons LLP
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Canada, USA
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April 2 2013

In 2012-0449371I7, the Canada Revenue Agency (CRA) confirmed that a both an upstream and a downstream absorptive merger under US corporate law would

Recent developments for the fourth quarter 2012

Baker & McKenzie
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Austria, Belgium, Canada, China, Ireland, Luxembourg, Malaysia, Morocco, Philippines, Singapore, South Korea, Spain, United Kingdom, USA
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March 18 2013

The North American Global Equity Services ("GES") practice group is pleased to provide the current edition of our Clients and Friends Newsletter

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

Anti-inversion regulations severely limit substantial business activities exception, as illustrated with Canada

Davies Ward Phillips & Vineberg LLP
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Canada, USA
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August 10 2012

In 2004, Congress enacted 7874 to put an end to certain perceived abuses associated with ‘‘inversion transactions,’’ i.e., transactions in which a U.S.-based multinational corporation migrates to a lower-tax jurisdiction in order to reduce U.S. taxation

Recent developments for the fourth quarter 2011

Baker & McKenzie
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Canada, China, Denmark, European Union, France, Germany, Ireland, Italy, Japan, Netherlands, Switzerland, United Kingdom, USA
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March 15 2012

The end of the year and beginning of a new year is always a busy time for us, as it is for most of our clients

Trend 2: Corporate spinoffs will continue to be an attractive way to return value to shareholders

Torys LLP
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Canada, USA
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January 4 2012

The year 2011 saw a record number of spinoff transactions as companies searched for ways to return value to shareholders in the face of challenging market conditions

Capital markets 2011 mid-year report

Torys LLP
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Canada, USA
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July 27 2011

To date, 2011 has been an exciting year in North American capital markets

The Canadian leasing environment: an overview for US professionals (business and legal)

Cassels Brock & Blackwell LLP
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Canada, USA
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May 5 2011

As international trade grows, financial institutions and manufacturers of equipment recognize that international sales or globalization of their business is a requirement to staying competitive

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

New U.S. foreign tax credit limitation applies to acquisitions of Canadian companies

Osler, Hoskin & Harcourt LLP
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Canada, USA
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February 2 2011

Effective January 1, 2011, new U.S. legislation limits the foreign tax credits available to a U.S. corporation that directly or indirectly acquires a Canadian corporation in certain basis step-up acquisitions

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Search results

CRA confirms tax treatment of US downstream absorptive merger

Recent developments for the fourth quarter 2012

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

Anti-inversion regulations severely limit substantial business activities exception, as illustrated with Canada

Recent developments for the fourth quarter 2011

Trend 2: Corporate spinoffs will continue to be an attractive way to return value to shareholders

Capital markets 2011 mid-year report

The Canadian leasing environment: an overview for US professionals (business and legal)

Canadian investment in U.S.-based private equity funds: preference for the U.S. limited liability company

New U.S. foreign tax credit limitation applies to acquisitions of Canadian companies

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