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Results: 1-10 of 34

Purchase of US vacation properties by Canadians

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • December 22 2009

Given the attractive U.S. real estate market, the strong Canadian dollar and low interest rates, more and more Canadians are purchasing U.S. vacation properties

Some guidance from Canada Revenue Agency on application of Fifth Protocol to unlimited liability companies and limited liability companies

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • December 31 2009

On November 24, 2009, the Canada Revenue Agency (“CRA”) provided some guidance on certain issues related to the application of the new hybrid rules in the Fifth Protocol to the Canada-US Tax Treaty (the “Treaty”) to Canadian unlimited liability companies (“Canadian ULCs”) (i.e. Nova Scotia, Alberta and British Columbia ULCs) and US limited liability companies (“US LLCs”

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

Arizona state’s new immigration laws - how do they affect Canadians?

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • July 31 2010

On April 23, 2010, Arizona Governor Jan Brewer, signed Bill 1070 into lawa move that is being called the toughest crackdown on illegal immigration in American history

The UBS scandal: voluntary disclosure

  • Miller Thomson LLP
  • -
  • Canada, Switzerland, USA
  • -
  • December 3 2009

Unless you have stopped reading newspapers, watching television or listening to the radio then it is more than likely that you have heard something about the UBS scandal

Foreign corruption: the U.S. Department of Justice commences its largest prosecution to date

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • February 23 2010

In January, twenty-two executives and employees from a number of American companies were indicted for offences contrary to the U.S. Foreign Corrupt Practices Act

Arizona state’s new immigration lawshow do they effect Canadians?

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • May 31 2010

On April 23, 2010, Arizona Governor Jan Brewer, signed Bill 1070 into lawa move that is being called the toughest crackdown on illegal immigration in American history

United States estate tax in 2010

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • May 14 2010

Federal estate tax in the United States is in a state of flux

Buy American

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • May 27 2010

In the September, 2009 issue of this newsletter, we explained the problems for Canadian companies with the “Buy American” clause in the U.S. government's $700-billion economic stimulus package (the American Recovery and Reinvestment Act of 2009

Guaranteed replacement cost coverage denied when insureds decide to relocate

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • January 20 2014

March 11, 2009 - a disastrous day for Mr. And Mrs. Willoughby. Their home was destroyed by fire. And while they might have moved back and had their