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Article

McCarthy Tétrault LLP | USA, Canada | 10 Jul 2017

SCOTUS Agrees to Hear Constitutional Challenge of Inter Partes Review Procedure for Patents

Canadian hydraulic fracturing technology (“fracking”) is at the center of a controversial US case about inter partes review (“IPR”) of patents. The

Article

McCarthy Tétrault LLP | United Kingdom | 3 Dec 2015

Anson v. HMRC: another approach to LLCs

On July 1st, 2015 the UK Supreme Court released its judgment in the case of Anson v. Commissioners for Her Majesty’s Revenue and Customs (Anson), in

Article

McCarthy Tétrault LLP | Canada | 8 May 2014

Federal Court of Appeal confirms narrow scope of paragraph 95(6)(b) Lehigh Cement

The Federal Court of Appeal recently issued its decision in a case that considered the scope of a specific anti-avoidance rule in paragraph 95(6)(b)

Article

McCarthy Tétrault LLP | Canada | 7 Feb 2014

“Stop and identify” yourself, to avoid personal liability when acting on behalf of a company

Third parties must know exactly who they are entering into a contract with, especially when dealing with a limited liability company. That said, the

Article

McCarthy Tétrault LLP | Canada | 8 Mar 2011

"Earnings" and single-member LLCs: where do we start?

Regulations to the Income Tax Act (Canada) (Act) contain rules with respect to the computation of the earnings of a foreign affiliate of a Canadian-resident taxpayer, which is relevant in calculating the surplus accounts of the foreign affiliate.

Article

McCarthy Tétrault LLP | Canada | 3 Nov 2010

Late-filing penalties for non-resident corporations

On June 11, 2010, the Federal Court of Appeal in Exida.com Ltd. Liability Co. v. Her Majesty the Queen (2010 DTC. 6935) resolved two conflicting decisions of the Tax Court of Canada on the issue of whether a non-resident corporation that does not have any tax payable under the Tax Act may be subject to a late-filing penalty for failing to file an income tax return within the prescribed time in the Tax Act.

Article

McCarthy Tétrault LLP | USA, Canada | 3 Nov 2010

US LLCs may claim refunds in certain circumstances

The Canada Revenue Agency (CRA) recently announced that it will accept claims for treaty benefits by US limited liability companies (LLCs) in certain circumstances.

Article

McCarthy Tétrault LLP | USA, Canada | 26 Apr 2010

US LLCs limited opportunity?

The April 8, 2010 decision of the Tax Court of Canada in TD Securities (USA) LLC v. R. (2008-2314(IT)G) has reversed a long-standing position of the Canada Revenue Agency (CRA) that US limited liability companies (LLCs) are not entitled to the benefits of the Canada-US Income Tax Convention (Treaty) before the recent amendments made in the Fifth Protocol to the Treaty.

Article

McCarthy Tétrault LLP | USA, Canada | 30 Sep 2009

Planning for the entry into force of treaty changes affecting hybrid entities on January 1, 2010

The Fifth Protocol to the Canada-US Tax Convention, 1980 (Canada-US Treaty) introduced important changes of interest to US multinational enterprises with hybrid entities, such as unlimited liability companies (ULCs) and limited liability companies (LLCs), in their cross-border structures.

Article

McCarthy Tétrault LLP | USA, Canada | 23 Feb 2009

Effective dates of the Fifth Protocol to the Canada-US Income Tax Convention

On December 15, 2008, the Fifth Protocol to the Canada - US Income Tax Convention (Treaty) came into force.

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