Canadian companies should carefully structure and document loans and advances to their U.S. subsidiaries. If loans to U.S. subsidiaries are not properly structured and documented, such loans may be recharacterized as equity...more
8/18/2017
/ Canada ,
Contract Terms ,
Corporate Taxes ,
Debt-Equity ,
Foreign Subsidiaries ,
Loan Agreements ,
Loan Documentation ,
Multinationals ,
Recharacterization ,
Subsidiaries ,
Transfer Pricing
Challenges of Transferring IP Offshore -
What constitutes intellectual property (“IP”) has long been a contested issue in tax practice, but generally includes intangible assets as wide-ranging as patents, copyrights,...more
4/18/2016
/ Exceptions ,
Foreign Subsidiaries ,
Intra-Group Transactions ,
IRS ,
Patents ,
PFIC ,
Portability ,
Proposed Regulation ,
Royalties ,
Subpart F ,
Tax Reform ,
Transfer of Assets ,
U.S. Treasury