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Fox Rothschild LLP | USA, Canada | 8 Nov 2011

New technical interpretation issued by Canada Revenue Agency on stock options will spark debate

A recent technical interpretation issued by the Canada Revenue Agency, Technical Interpretation 2011-0393411E5, provides that under Article XV of the Canada-U.S. Income Tax Convention, that after 2008, when a U.S. resident employee of a Canadian resident corporation acquires shares of the corporation on the exercise of employee stock options, the Canada Revenue Agency (CRA) would disallow that the income from the taxable amount would qualify for exemption from Canadian income tax under the Canada-U.S. Tax Treaty, even if the employer was not present in Canada for more than 183 days.


Fox Rothschild LLP | USA | 13 Sep 2011

Non-resident sellers of Canadian taxable property pose challenges despite recent reforms announced by Canada

Under 116 of The Canadian Income Tax Act (“CITA”), non-residents who dispose of certain taxable Canadian property, aka “Canadian Taxable Property”, must notify the Canada Revenue Agency (“CRA”) of the pending sale either prior to the disposition or within 10 days after the closing


Fox Rothschild LLP | USA | 16 Feb 2011

New estate tax rules for deaths that occurred in 2010

In December 2010, we issued an alert informing you of the passage of the Tax Relief Unemployment Insurance Reauthorization and Job Creation Act of 2010, which directly impacted income, gift, estate and generation skipping transfer (GST) taxation for 2010, 2011 and 2012.


Fox Rothschild LLP | USA | 21 Dec 2010

Significant modifications made to the federal estate & gift tax

On Friday, December 17, 2010, President Obama signed into law the Tax Relief Unemployment Insurance Reauthorization and Job Creation Act of 2010 (Tax Relief Act), which reinstates the federal estate and generation skipping transfer taxes effective for decedents dying and transfers made after December 31, 2009.


Fox Rothschild LLP | USA | 26 Oct 2010

Two items of note with regard to plan loans

In late September 2010, the Financial Accounting Standards Board (FASB) approved its position that participant loans from defined contribution plans (profit sharing, 401(k) and money purchase pension plans) should be classified, for financial reporting purposes, as receivables.

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