Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Spotlight Series: Beyond the Technical Side of Tax Law
10 Things Lawyers Should Know About BVI Transactions
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
The Biden Tax Plan
Tax Planning Under a Biden Presidency
2020 Presidential Candidates' Tax Proposals
New anti-abuse provisions
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Impact of environmental, social and governance agenda on tax
Our Doing Business in Québec guide provides an overview of the legal framework governing Canadian business operations in the province of Québec. This guide provides up-to-date information about the following topics: •...more
The Canadian Department of Finance introduced draft legislation in the 2023 Canadian Federal Budget (Budget 2023) to create employee ownership trusts (EOTs) to facilitate the transfer of a business to the employees of the...more
Le 4 août 2023, le ministère des Finances (le « ministère ») a publié de multiples propositions législatives et notes explicatives connexes (les « propositions du 4 août »). Ces propositions du 4 août comprennent des...more
On August 4, 2023, the Department of Finance (Finance) released a significant package of draft legislative proposals and related explanatory notes (August 4 Proposals). The August 4 Proposals include updated legislative...more
With the enactment of Bill C-47 on June 22, 2023, Canada's enhanced mandatory disclosure rules are now fully in effect. These rules, which were first announced in the 2021 Canadian federal budget...more
As discussed in our previous blog post, Unpaid Municipal Taxes Will Impact New AER Licenses and License Transfers, the Alberta Minister of Energy released Ministerial Order 043/2023 (the Order) on March 16, 2023. The Order...more
In November 2022, we wrote about the federal government's proposal in the 2022 Fall Economic Statement to tax share buybacks by public corporations in our blog, Canada Proposes New Tax On Share Buybacks. At the time, few...more
On March 20, 2023, the Alberta Minister of Energy, Peter Guthrie, released ministerial order 043/2023 (the Order). The Order, authorized pursuant to the Responsible Energy Development Act, requires the Alberta Energy...more
The new year has brought with it some important tax changes for businesses and residential property owners in Canada....more
Alberta is launching a new agri-processing tax credit in Spring 2023 to attract new large-scale investment to the sector and expand opportunities for primary producers....more
Key Highlights - - Proposed 30 percent refundable Clean Technology Investment Tax Credit. - Proposed refundable Clean Hydrogen Investment Tax Credit. - Further details and consultations are forthcoming. -...more
The federal government's 2022 Fall Economic Statement (Economic Statement), released on November 3, 2022, introduced a new tax on share buybacks by public corporations in Canada. Under the proposal, which would come into...more
Potash is a critical mineral used as a replenishing agricultural fertilizer. As a result, millions of farmers around the world depend on potash. The Canadian province of Saskatchewan is the world's largest potash producer,...more
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
The 2022 Canadian Federal Budget, released on April 7, 2022, sets the fundamental groundwork of the Government of Canada's goals for national economic development. Following Canada's announcement of its 2030 Emissions...more
On April 7, 2022 (Budget Day), the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2022), the second budget since the start of the...more
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 December 8, 2021, Alberta proclaimed in force Bill 77, the Municipal Government (Restoring Tax Accountability) Amendment Act, 2021 (the Amending Act), which is intended to strengthen municipal budgets following reports by...more
Due to the complexity of Canadian tax law, it is not uncommon for taxpayers and the minister of national revenue to refine their respective positions and identify new arguments and issues in the course of the tax dispute...more
On December 6, 2021, the Federal Court of Appeal (“FCA”) affirmed the Federal Court’s decision in Denso Manufacturing Canada Inc. v. Canada (National Revenue), which had dismissed the taxpayers’ application for judicial...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 the recently released Budget 2021, Canada's federal government announced its plan to continue with the development of a Digital Services Tax (DST) to be imposed on certain large taxpayers. The DST is proposed to apply at a...more
Plus de deux ans après le dernier budget fédéral, la ministre des Finances du Canada a présenté le budget fédéral de 2021 (le « Budget 2021 »), le 19 avril 2021 (le « jour de dépôt du budget »). Certains commentateurs ont...more
The 2021 Canadian Federal Budget, released on April 19, 2021, proposes new rules that would fundamentally alter the interest deductibility landscape for Canadian businesses. The thrust of the new rules (referred to herein as...more
More than two years after the last federal budget, Canada’s Finance Minister presented the 2021 budget (Budget 2021) on April 19, 2021 (Budget Day). Some commentators speculated that Budget 2021 might include increases in the...more