On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more
2/27/2020
/ Anti-Avoidance ,
Capital Gains ,
Corporate Taxes ,
GAAR ,
Income Taxes ,
International Tax Issues ,
OECD ,
Principal Purpose Test ,
Private Equity Firms ,
Tax Treaty ,
Withholding Tax
On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). As noted in our...more
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