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Results:1-10 of 17

Important note to US investors into Canada using hybrid entities
  • Gowling WLG
  • USA, Canada
  • May 28 2009

Canadian unlimited liability companies ("ULCs") have been used for some time now by US-resident investors into Canada for a variety of reasons, including to finance Canadian activities.


Fixed and floating charge holders cannot participate in prescribed part for shortfalls
  • Gowling WLG
  • United Kingdom
  • February 8 2008

Secured creditors with an unsecured shortfall cannot claim a share of the prescribed part of the floating charge realisations set aside for unsecured creditors under Section 176A of the Insolvency Act 1986.


Impact of the new tax protocol on limited liability companies, unlimited liability companies and debt financing: opportunities and challenges in cross-border transactions
  • Gowling WLG
  • USA, Canada
  • October 10 2007

The Fifth Protocol to the Canada - U.S. Tax Convention, dated September 21, 2007 (the "Protocol") will have a significant impact on cross-border transactions given the proposed treatment for hybrids and the elimination of withholding tax on interest on arm's length cross-border debt.


Regulator and clearance: new draft guidance
  • Gowling WLG
  • United Kingdom
  • September 30 2007

The Pensions Regulator introduced the clearance procedure in April 2005.


Update of Canadian interest deductibility proposals
  • Gowling WLG
  • Canada
  • July 23 2007

In the 2007 Federal Budget (delivered March 19, 2007) the Minister of Finance announced that new legislation would be introduced to restrict the deductibility of interest on funds borrowed by a Canadian corporation to finance a "foreign affiliate".


Budget 2007: individuals
  • Gowling WLG
  • United Kingdom
  • March 22 2007

The headline is of course the reduction in the basic rate of income tax to 20 from 2008-09.


Eglantine Lioret
  • Gowling WLG

Ben Tennant
  • Gowling WLG

Greg Standing
  • Gowling WLG

Lee Nuttall
  • Gowling WLG