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Thought leadership
- Miller Thomson LLP
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- Canada, USA
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- February 1 2011
On January 25, 2011, the National Round Table on the Environment and the Economy (“NRTEE”) released its report: Climate Prosperity- Parallel Paths: Canada- U.S. Climate Policy Choices
Is the provision of fertility charitable?
- Miller Thomson LLP
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- Canada, USA
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- December 31 2010
At the end of September of this year, the City of Toronto had the pleasure of hosting the American Bar Association Tax Conference
Cross-border tax: Canada-US Tax Treaty update CRA views on treaty entitlement on Canadian source income and profit for US LLC shareholders
- Miller Thomson LLP
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- Canada, USA
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- October 5 2010
The Canada Revenue Agency ("CRA") recently confirmed that it continues to maintain its long-standing position that a US limited liability company ("US LLC") that is treated as a fiscally transparent entity for US tax purposes is not entitled to treaty benefits under the Canada-US Tax Treaty, as amended by the Fifth Protocol ("Treaty"
Tax Information Exchange Agreements - overview and update
- Miller Thomson LLP
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- Canada, USA
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- October 5 2010
Most international tax treaties entered into by Canada include a tax information exchange provision (e.g., Article XXVII of the Canada-US Tax Treaty) that enables the Canada Revenue Agency (“CRA”) to obtain pertinent tax information about a particular taxpayer from a foreign country or jurisdiction
Arizona state’s new immigration laws - how do they affect Canadians?
- Miller Thomson LLP
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- Canada, USA
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- 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
Canadian tax refunds for U.S. limited liability companies
- Miller Thomson LLP
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- Canada, USA
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- 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 lawshow do they effect Canadians?
- Miller Thomson LLP
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- Canada, USA
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- 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
Buy American
- Miller Thomson LLP
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- Canada, USA
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- 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
United States estate tax in 2010
- Miller Thomson LLP
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- Canada, USA
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- May 14 2010
Federal estate tax in the United States is in a state of flux
Foreign corruption: the U.S. Department of Justice commences its largest prosecution to date
- Miller Thomson LLP
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- Canada, USA
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- 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
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