Corporate Taxes, Tax Treaty, Capital Gains

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Davies Ward Phillips & Vineberg LLP on 3/4/2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

Federal Court of Appeal Upholds Treaty-Based Canadian Holding Structure

Bennett Jones LLP on 2/27/2020

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

Tax Court Affirms Treaty-Based Canadian Holding Structure

Bennett Jones LLP on 9/5/2018

The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains and that the general anti-avoidance rule ("GAAR") did not...more

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

Bilzin Sumberg on 9/28/2016

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

European M+A News, Winter 2016

Morrison & Foerster LLP on 2/11/2016

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

"Senate Finance Committee Takes Unanimous Step Toward FIRPTA Reform"

Skadden, Arps, Slate, Meagher & Flom LLP on 2/14/2015

On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more