John Hollinrake Jr.

Dorsey & Whitney LLP

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Latest Posts › Cross-Border Transactions

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Cross-Border de-SPAC Structures

More special purpose acquisition vehicles (common known as “SPACs”) completed their initial public offering (“IPO”) in 2021 than in any prior year. In 2021, approximately 613 SPACs completed their IPO within the United States...more

7/5/2022 / Acquisitions , Canada , Cross-Border , Cross-Border Transactions , Initial Public Offering (IPO) , International Tax Issues , Special Purpose Acquisition Companies (SPACs) , Tax Haven

Plan Ahead to Reduce (or Eliminate) U.S. Withholding Tax when Selling or Transferring U.S. Subsidiaries holding U.S. Real Property

Many Canadian companies and individuals own U.S. real property interests through a U.S. corporation. The Foreign Investment in Real Property Tax Act (“FIRPTA”) regime imposes a withholding tax (currently at a rate as high as...more

2/1/2022 / Cross-Border Transactions , FIRPTA , IRS , Real Estate Transactions , Real Estate Transfers , Required Forms , Subsidiaries , Withholding Tax

Share Buyback Transactions: U.S. Tax Consequences may differ for each U.S. Shareholder

On Thursday, November 4, 2021, the Office of the Superintendent of Financial Institutions announced that, subject to approval by the superintendent, Canadian banks and other financial institutions may begin repurchasing their...more

11/12/2021 / Canada , Corporate Taxes , Cross-Border Transactions , Financial Institutions , Foreign Corporations , Passive Foreign Investment Company , Publicly-Traded Companies , Share Buybacks , Shareholders , Stock Repurchases

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