We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
Lexology logo






  Request new password

Search results

Order by most recent / most popular / relevance

Results: 1-9 of 9

New protocol to the Canada-US tax treaty: recognition of LLCs and elimination of treaty benefits for certain hybrid entities

  • McMillan LLP
  • -
  • Canada, USA
  • -
  • October 26 2007

On September 21, 2007, Canada and the United States signed the long-awaited Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”

Things just changed: new considerations for establishing a presence in Canada

  • Cassels Brock & Blackwell LLP
  • -
  • Canada, USA
  • -
  • December 3 2007

The signing of the Fifth Protocol to the Canada-U.S. Tax Treaty (the "Treaty") and the coming into force of the unlimited liability company provisions of the British Columbia Business Corporations Act in October 2007 may affect the manner in which American business enters the Canadian market

Canadian tax refunds for U.S. limited liability companies

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • July 9 2010

Before the Fifth Protocol amendments to the Canada-US Income Tax Convention (the Treaty), the Canada Revenue Agency (CRA) maintained that a fiscally transparent US limited liability company (LLC) was not entitled to Treaty benefits because the U

BLG Monthly Update

  • Borden Ladner Gervais LLP
  • -
  • Argentina, Australia, Canada, United Kingdom, USA
  • -
  • December 19 2012

The BLG Monthly Update is a digest of recent developments in the law which Neil Guthrie, our National Director of Research, thinks you will find

New life for income trusts?

  • Blake Cassels & Graydon LLP
  • -
  • Canada, USA
  • -
  • February 7 2012

2011 saw the emergence of variations of income funds that avoid the SIFT rules that tax income from non-portfolio property

Recent developments for the fourth quarter 2011

  • Baker & McKenzie
  • -
  • Canada, China, Denmark, European Union, France, Germany, Ireland, Italy, Japan, Netherlands, Switzerland, United Kingdom, USA
  • -
  • 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

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

  • Davies Ward Phillips & Vineberg LLP
  • -
  • Canada, USA
  • -
  • 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

CRA considers US LLC and Canadian branch tax

  • Thorsteinssons LLP
  • -
  • Canada, USA
  • -
  • January 7 2013

The CRA does not consider a US limited liability company (LLC) itself to be a resident of the US for purposes of benefits under the Canada-US tax treaty

CRA comments on US company holding inventory in Canada

  • Thorsteinssons LLP
  • -
  • Canada, USA
  • -
  • January 7 2013

In 2012-0438691E5, the Canada Revenue Agency (CRA) considered a US corporation (US Co) that shipped inventory to an unaffiliated customer's warehouse in

Current Search

Suggested Facets

Author

Firm Name

Jurisdiction

Workarea

© Copyright 2006-2013 Globe Business Publishing Ltd | Cookies | Disclaimer | Privacy policy