On January 1, 2024, new direct reporting requirements to the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of the Treasury, became effective – known as the Corporate Transparency...more
1/31/2024
/ Beneficial Owner ,
Business Entities ,
Canada ,
Corporate Issuers ,
Corporate Transparency Act ,
Effective Date ,
Exemptions ,
Filing Deadlines ,
FinCEN ,
Foreign Issuers ,
Form 10-K ,
NYSE ,
Reporting Requirements ,
Securities Exchange Act ,
Subsidiaries
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
3/16/2023
/ Affiliates ,
Anti-Inversion Regulations ,
Canada ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
IRS ,
New Guidance ,
Publicly-Traded Companies ,
Stock Repurchases ,
Subsidiaries ,
U.S. Treasury
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
8/23/2022
/ Biden Administration ,
Canada ,
Corporate Taxes ,
Covered Entities ,
Domestic Corporations ,
Excise Tax ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
IRS ,
Publicly-Traded Companies ,
Share Buybacks ,
Stock Repurchases ,
U.S. Treasury
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
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
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
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
A Canadian which holds a partnership interest in a U.S. or non-U.S. partnership that has “effectively connected income” (“ECI”) is subject to U.S. tax withholding with respect to the Canadian partner’s allocable share of the...more
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
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