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Dorsey & Whitney LLP

Canadian Compensation Arrangements - When Do I Need U.S. Counsel?

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Imagine a Canadian company adopts a deferred share unit plan (DSU Plan) for its directors.  At the time the plan is adopted, the company does not have the plan reviewed by U.S. counsel, because none of their directors reside...more

Dorsey & Whitney LLP

Initial Guidance for New U.S. Excise Tax on Stock Repurchase Transactions: IRS Substantially Expands Scope of Applicable Canadian...

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In our blog post dated August 22, 2022, we discussed the one percent (1%) excise tax on certain stock repurchase transactions by certain publicly traded corporations enacted as part of the Inflation Reduction Act of 2022 (the...more

Rivkin Radler LLP

Foreign Individuals Holding U.S. Real Property, or Left Holding the Bag?

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There have been some interesting developments of late with respect to the ownership of real property in parts of the English-speaking world. For example, Canada has imposed a temporary ban on the purchase of such property by...more

Dorsey & Whitney LLP

Inflation Reduction Act: New U.S. Excise Tax on Stock Repurchase Transactions Applicable to Certain Canadian Companies

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On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by certain...more

Dorsey & Whitney LLP

Canadian Corporations Acquiring U.S. Target Companies in Tax-Deferred Transactions: When Business Activities Outside the U.S....

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In transactions in which a Canadian corporation seeks to acquire a U.S. target entity for shares of the Canadian acquiror in a transaction intended to be tax-deferred for U.S. federal income tax purposes, the ability of U.S....more

Dorsey & Whitney LLP

Critical Reporting Obligation: Canadian-Owned U.S. Corporations and Disregarded Entities

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Canadian persons and entities owning a significant interest in a U.S. corporation or U.S. entity classified as a “disregarded entity” for U.S. federal income tax purposes should ensure they are compliant with IRS Form 5472...more

Dorsey & Whitney LLP

COVID-19 Delays EIN Process for Canadian Applicants

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Current closures at the Internal Revenue Service (“IRS”) have caused significant delays in obtaining an Employer Identification Number (“EIN”) for some U.S. businesses formed by Canadians, including new U.S. subsidiaries...more

Seyfarth Shaw LLP

The Week in Weed: April 2020 #2

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COVID-19 continues to dominate the news – no surprise there.  Whether it’s federal relief or state legalization roadblocks, the virus is everywhere.  But there is some other news: the IRS seems likely to increase auditing of...more

Dorsey & Whitney LLP

Stranded Canadians Taxed in the Time of Covid-19

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As Covid-19 continues to spread, many countries, including the United States and Canada, are increasingly closing their borders in an attempt to slow the rate of infection. This precaution may, however, have unintended tax...more

Seyfarth Shaw LLP

The Week in Weed: March 2020

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To cap or not to cap, that was the question facing the state of Florida this week.  Lawmakers wrestled with the issue of capping THC content in medical marijuana for those patients under the age of 21.  The Senate Rules...more

Perkins Coie

Blockchain Week in Review - July 2019

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U.S. Developments - Regulatory Developments - SEC and FINRA Issue Joint Statement on Digital Asset Custody Issues - On July 8, 2019, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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British lawmakers are voting today on Theresa May’s updated Brexit plan, and by all accounts, it’s been a mad dash for the Prime Minister in recent weeks to shore up support for a plan “that could go down to a humiliating...more

Jones Day

Jones Day Global Privacy & Data Security Update | Vol. 19

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On the heels of the European Union's General Data Protection law, which went into effect in May 2018, California has enacted the California Consumer Privacy Act ("CCPA")—the result of an 11th-hour compromise between...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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More on the rather shocking departure of John Flannery from GE, the Board that didn’t want to give him any more leash for his turnaround plans, and the future of the embattled corporate giant under Larry Culp....more

Jones Day

Global Privacy & Cybersecurity Update Issue 18 | June 2018

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JONES DAY CYBERSECURITY, PRIVACY & DATA PROTECTION ATTORNEY SPOTLIGHT: Richard Martinez - Europe's new General Data Protection Regulation ("GDPR") is driving an evolution in corporate privacy practices globally. As...more

Morrison & Foerster LLP - Structured Products

Structured Thoughts: News for the financial services community Volume 9, Issue 3

FINAL CANADIAN BAIL-IN RULES: IMPACT ON STRUCTURED NOTES OFFERED IN THE UNITED STATES - In March 2018, the Canadian government released its final regulations relating to “bail-in instruments” issued by Canadian...more

Holland & Knight LLP

Federal Court Rejects Efforts to Diminish Measures Aimed at Reducing Offshore Tax Avoidance

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As of January 1, 2013, United States banks were required to report to the IRS interest earned by nonresident aliens who are residents of certain foreign countries. The reporting requirement previously existed for accounts...more

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