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New tax issues for foreign buyers

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • March 6 2013

One of the most important considerations for M&A purchasers (especially in cross-border transactions) is managing tax issues

Spin-outs in M&A: bridging the valuation gap

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • February 6 2013

When companies are reportedly sitting on plenty of money, it might be expected that they would spend freely when it comes to acquisitions. However

M&A: what to expect in 2013?

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • January 31 2013

The beginning of a new year is an occasion for looking back and for making predictions. In the M&A world, a look back on 2012 is striking because of

Goodwill hunting: identifying and allocating value to goodwill on the sale of a business

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • February 16 2012

One of the more significant issues in an asset purchase deal is the allocation of purchase price among the assets being purchased

LDCs now

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • December 7 2011

For more than a decade one would be hard pressed to find a slow period in the distribution sector

Taxable Canadian property changes facilitate inbound investment

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • April 16 2010

Foreign investors, particularly private equity funds, have long had to deal with the complexity of the reporting requirements under section 116 of the Income Tax Act (Canada) (the "Tax Act") when disposing of investments that are taxable Canadian property ("TCP"), such as shares of private Canadian companies

2010 Canadian Budget amendments - foreign investment in life sciences sector

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • March 29 2010

Foreign investors, particularly private equity funds, have long complained about the complexity of dealing with the reporting requirements under section 116 of the Income Tax Act (Canada) (the "Tax Act") with respect to the disposition of investments which represent taxable Canadian property ("TCP"), such as shares of private Canadian companies

Continuing issues for U.S. LLCs investing into Canada

  • Borden Ladner Gervais LLP
  • -
  • Canada, USA
  • -
  • March 18 2010

The Canada Revenue Agency (“CRA”), on February 11, 2010, issued a Technical Memorandum on the application by Canada of the look-through rule in Article IV(6) of the Canada-U.S. Income Tax Convention (the “Treaty”) to U.S. limited liability companies (LLCs) and their members

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

New tax landscape requires innovative planning

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • September 30 2008

The past year has seen significant developments in Canada's international tax rules affecting both inbound and outbound investment, with the promise of more to come