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Results: 1-10 of 346

Canada and U.S. finally reach agreement on FATCA
  • Hodgson Russ LLP
  • Canada, USA
  • February 7 2014

The long awaited Foreign Account Tax Compliance Act United States - Canada Intergovernmental Agreement (IGA) was released on February 5, 2014, and as

Why is it so hard to sue trustees of a REIT?
  • Borden Ladner Gervais LLP
  • Canada, USA
  • September 21 2015

Owners of units in a REIT or income trust, if they think about it all, think of themselves as being like shareholders of a public corporation. This

IRS reports on the success of its voluntary disclosure programs
  • Stikeman Elliott LLP
  • Canada, USA
  • October 19 2015

Since the initiation of the U.S.Internal Revenue Service's (IRS) Offshore Voluntary Disclosure Program (OVDP) which originally began in 2009 and the

Oversight or fiduciary managers
  • McCarthy Tétrault LLP
  • Canada, USA
  • June 30 2014

There is a new kid on the block. Some employers sponsoring large andor multiple registered pension plans (RPPs) have recently begun outsourcing most

CRA publishes FATCA guidance for Canadian entities
  • Stikeman Elliott LLP
  • Canada, USA
  • July 3 2014

The Canada Revenue Agency (CRA) on June 23, 2014 posted much anticipated guidance for Canadian entities that could find themselves subject to the

IRS publishes instructions for FATCA form W-8BEN-E
  • Stikeman Elliott LLP
  • Canada, USA
  • June 26 2014

The long awaited instructions for Form W-8BEN-E, Certification of Foreign Status of Beneficial Owner for United States Tax Withholding (Entities

New protocol to the Canada-US Tax Treaty: taxpayer emigration
  • McMillan LLP
  • Canada, USA
  • October 26 2007

One of the notable features of the Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”) are the new provisions that are designed to prevent the double taxation of pre-emigration gains on property held by an emigrant

Moving to the United States: tax consequences and planning opportunities
  • Gowling Lafleur Henderson LLP
  • Canada, USA
  • June 15 2008

Moving to the United States may raise all sorts of concerns for individuals resident in Canada, not the least of which are the potential tax consequences to such a move

Recent developments for the fourth quarter 2011
  • Baker & McKenzie
  • Canada, China, Japan, Netherlands, Switzerland, United Kingdom, USA, Denmark, European Union, France, Germany, Ireland, Italy
  • 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

More on FATCA and more to come: the Internal Revenue Service and Treasury Department release proposed regulations
  • McCarthy Tétrault LLP
  • Canada, USA
  • April 2 2012

In 2010, the United States amended the Internal Revenue Code of 1986 to add provisions relating to foreign account tax compliance (FATCA