Multinational corporations, cross-border investments and many other Canadian public and private enterprises, will likely soon face a new and complex interest expense deduction limitation in Canada....more
On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more
5/31/2019
/ Anti-Avoidance ,
BEPS ,
Canada ,
Capital Gains ,
Energy Sector ,
Foreign Investment ,
International Tax Issues ,
OECD ,
Private Equity Firms ,
Tax Treaty ,
Withholding Tax
Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures contained in the...more
4/4/2019
/ Anti-Avoidance ,
Capital Gains ,
Foreign Investment ,
International Tax Issues ,
Multilateral Agreement ,
OECD ,
Principal Purpose Test ,
Private Equity Firms ,
Ratification ,
Tax Agreements ,
Tax Treaty
In the Canadian Federal Budget released on February 11, 2014, the Department of Finance signaled its intention to enact a domestic treaty-shopping rule, generally allowing the Canada Revenue Agency (CRA) to deny treaty...more