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Results: 1-10 of 47

Family resemblance: When is a promissory note not a “security”?
  • Gowling WLG
  • USA, Canada
  • March 30 2017

For financing lawyers, the precise dividing line between the simple fluidity of financing law and the highly meticulous application of securities


Guide to Doing Business in Canada: Mergers & acquisitions
  • Gowling WLG
  • USA
  • October 14 2016

Canada is an ideal location in which to establish and grow a business, including by way of mergers and acquisitions. There are a number of advantages


New disclosure requirements and added relief for U.S. taxpayers with undisclosed foreign assets
  • Gowling WLG
  • USA, Canada
  • March 9 2012

The U.S. government has recently embarked on an aggressive campaign to reduce international tax evasion by U.S. citizens or permanent residents with undisclosed income and assets located in foreign countries


Dual consolidated loss rules can apply to Article IV(7)(b) restructured debt
  • Gowling WLG
  • USA, Canada
  • June 22 2011

Because Article IV(7)(b) of the Canada-U.S. Tax Treaty (the “Treaty”) generally results in a loss of treaty benefits on interest payments from a ULC to its U.S. parent (“USCo”) where the ULC is fiscally transparent for U.S. tax purposes, the USCo will generally restructure its cross border debt in order to avoid that result


Article XIII(8) of the Canada-U.S. treaty not a simple rollover provision
  • Gowling WLG
  • USA, Canada
  • May 4 2011

The purpose of this article is to provide an update on current developments at the Canadian Competent Authority regarding Article XIII(8) of the Canada-United States Tax Convention (1980) (“Convention”) and similar provisions found in other Canadian tax treaties


Current developments regarding Article XIII(8) of the Canada-U.S. treaty: from the perspective of dispositions of taxable Canadian property - Part I
  • Gowling WLG
  • USA, Canada
  • April 30 2011

The purpose of this article is to provide an update on current developments at the Canadian Competent Authority regarding Article XIII(8) of the Canada-United States Tax Convention (1980)1 ("Convention") and similar provisions found in other Canadian tax treaties


Canada and the U.S.: differences in competition law
  • Gowling WLG
  • USA, Canada
  • November 10 2010

Competition Act is a federal statute administered by the Competition Bureau; there is no other related federal or provincial legislation


Executives fined under books and records provision of the Foreign Corrupt Practices Act as "control persons"
  • Gowling WLG
  • USA, Canada
  • November 25 2009

On July 31, 2009, the U.S. Securities & Exchange Commission (SEC) settled an enforcement action in which a company's COO and CFO had been charged under the U.S. Foreign Corrupt Practices Act (FCPA) and the U.S. Securities Exchange Act for violations of anti-bribery, books and records, and internal control provisions under these Acts


Obama's tax plan and the repercussion for transfer pricing
  • Gowling WLG
  • USA
  • September 21 2009

Now, more than ever, transfer pricing must be at the forefront of tax decisions for multinational enterprises (MNEs


The Investment Company Act of 1940
  • Gowling WLG
  • USA, Canada
  • August 17 2009

Canadian technology companies often seek funding from U.S. venture capital funds (VCs