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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

CanadaU.S. treaty could impact Japan-North American investments

  • Borden Ladner Gervais LLP
  • -
  • Canada, Japan, USA
  • -
  • January 14 2010

Any structuring of investments by Japanese investor into Canada through the U.S., or any acquisition of a U.S. business which either operates a Canadian business or which receives Canadian-sourced payments, and any decision to acquire a Canadian business or to expand Canadian operations where business arrangements and particularly intercompany funding result in a U.S. resident receiving Canadian-sourced cash flows should include a review of how the Limitation on Benefits (“LOB”) rules in the recently revised Canada-U.S. Income Tax Convention (the “Treaty”) may apply