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Our insurance group colleague Stuart Carruthers recently authored an article regarding the potential compliance issues emanating from certain provisions of the U.S. Hiring Incentives to Restore Employment Act known as the Foreign Account Tax Compliance Act
The Hiring Incentives to Restore Employment Act (or HIRE Act) has now come into effect in the United States and it will likely be relevant to Canadian participants in the OTC derivatives and securities lending areas
On December 14, 2007, the fifth Protocol to the Canada-U.S. Income Tax Convention (the "Treaty") was ratified by Canada when Bill S-2 received royal assent
As reported in Stikeman Elliott’s April 12, 2007 Structured Finance Update, it was announced in the March 2007 Federal Budget that an agreement in principle had been reached between Canada and the U.S. that would update the Canada-U.S. tax treaty with the effect of eliminating withholding tax on interest paid on arm’s length cross-border financings between Canada and the U.S
In his 2007 Canadian Federal Budget (the Budget), the Minister of Finance (the Minister) announced that an agreement in principle had been reached on a number of significant amendments to the Canada-U.S. Tax Convention (the Treaty) that deal with some long-standing impediments to cross-border transactions
