News & Analysis as of

Derivatives Tax Treaty

Blake, Cassels & Graydon LLP

2016 Federal Budget – Selected Tax Measures

On March 22, 2016, the Minister of Finance tabled Canada’s 2016 Federal Budget (the 2016 Budget). This was the first budget presented by the newly-elected Liberal government, which won a strong majority in the fall 2015...more

Dechert LLP

Financial Services Quarterly Report - Second Quarter 2015: OECD Discussion Draft on BEPS: Funds’ Treaty Access under Threat

Dechert LLP on

The Organisation for Economic Co-operation and Development (OECD) published a revised discussion draft on 22 May 2015, in relation to Action 6 of the BEPS (Base Erosion and Profit Shifting) Action Plan (Action Plan 6), which...more

Bilzin Sumberg

Editorial: Qualifying for Treaty Benefits Under the “Derivative Benefits” Article

Bilzin Sumberg on

Foreign persons are subject to U.S. federal income tax on a limited basis. Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on...more

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