Bill C-29 significantly expands back-to-back rules

Size: px
Start display at page:

Download "Bill C-29 significantly expands back-to-back rules"

Transcription

1 from International Tax Services Issue Bill C-29 significantly expands back-to-back rules November 16, 2016 In brief Bill C-29, Budget Implementation Act, 2016, No. 2, which received first reading on October 25, 2016, significantly expands the back-to-back rules for non-resident withholding tax. The bill, which is expected to be enacted before year end: clarifies the application of the rules to arrangements with multiple intermediaries adds character substitution rules extends the rules to address rents and royalties introduces back-to-back rules for shareholder loans These measures were originally introduced in the 2016 federal budget. They were released in draft form on July 29, 2016, and rereleased with some changes as a Notice of Ways and Means Motion on October 21, 2016 (October proposals). Affected taxpayers should be ready because the new rules will apply soon. In particular: the withholding tax changes (including the extension of the rules to back-to-back rents and royalties) apply to amounts paid or credited after 2016; these changes are relevant to interest, rents or royalties accrued in 2016 (or earlier) but paid after 2016 the new shareholder loan rules generally apply to debts outstanding after March 21, 2016 (as discussed in more detail below) This Tax Insights provides an overview of these highly complex changes. 1 In detail Background The existing back-to-back loan rules were introduced in the 2014 federal budget, applicable to interest paid or credited after They address back-to-back arrangements in the context of the non-resident withholding tax on interest (similar rules address back-to-back arrangements in the context of the thin capitalization rules). The rules apply to certain financing arrangements when: a non-resident person (the funder ) indirectly provides funding, in whole or in part, to a Canadian taxpayer through an intermediary, and interest paid by the taxpayer to the intermediary is subject to less withholding 1. For a more detailed discussion of the new rules, see Is the Back-to-Back Withholding Tax Regime an Effective Anti-Treaty Shopping Measure? by Ian Bradley, Denny Kwan and Dian Wang, in the upcoming issue of the Canadian Tax Journal.

2 tax than would be imposed if the interest were paid directly to the funder This may be the case when the intermediary deals at arm s length with the taxpayer (because arm s length interest payments are generally exempt from withholding tax under domestic law) or is entitled to more favourable tax treaty benefits as compared to the funder. The incoming funding, which is provided by the funder must be connected to the outgoing funding, which is provided by the intermediary to the taxpayer. Financing arrangements that may satisfy this connection test include: limited recourse debts the intermediary receives a loan from the funder, for which recourse is limited to the outgoing funding causal connections the intermediary provides the outgoing funding (or permits this funding to remain outstanding) because it (or a related person or partnership) receives a loan from the funder (or such a loan is permitted to remain outstanding), or because it anticipates that such a loan will be received (or remain outstanding) specified rights the funder grants the intermediary (or a related person or partnership) a specified right, which is connected to the outgoing funding; a specified right generally includes a right to use a property to secure payment of a debt (other than the debt of the Canadian taxpayer), or to use, invest, sell or otherwise dispose of a property, subject to certain conditions These conditions could be met for multiple funders who directly or indirectly have provided funding that funds, in whole or in part, the outgoing funding to the taxpayer. When these rules apply, the taxpayer is deemed to pay interest to each funder for purposes of the interest withholding tax rule (in addition to the actual interest paid to the intermediary). The amount of the deemed interest paid to each funder is equal to the actual interest paid to the intermediary, adjusted by a formula to reflect: the amount of the taxpayer s debt that is indirectly funded by the funder, and the difference between the withholding tax rates on interest paid to the funder and the intermediary Because the formula is applied to each funder, when there are multiple funders the aggregate deemed interest paid by the taxpayer could exceed the actual interest paid to the intermediary. When this occurs, the taxpayer can reduce the deemed interest allocated to each funder as is reasonable in the circumstances, to eliminate the effects of the excess funding. New withholding tax rules Multiple intermediaries Bill C-29 preserves the basic structure of the back-to-back loan rules, but makes several changes to accommodate arrangements involving multiple intermediaries and to address certain other issues. The amended back-to-back loan rules apply to certain arrangements in which one or more ultimate funders indirectly provide funding to a Canadian taxpayer, by way of a chain of funding arrangements involving one or more intermediaries. The connection required to link incoming funding received by an intermediary and outgoing funding provided by the intermediary is essentially the same as the test in the existing rules; however, this connection test can now apply iteratively to link a chain of funding with multiple intermediaries. Ultimate funders are generally persons or partnerships that provide net new funding in the chain of funding arrangements. Accordingly, an intermediary in the funding chain can also be an ultimate funder, when the amount of outgoing funding provided by the intermediary exceeds the amount of incoming funding received by the intermediary. However, if the intermediary has incoming funding equal to its outgoing funding, the intermediary s outgoing funding will not be subject to the amended rules. When the amended rules apply, the taxpayer is deemed to pay interest to each ultimate funder for purposes of the interest withholding tax rule. The amount of deemed interest is equal to the actual interest, adjusted by a formula to reflect: the proportion of the taxpayer s debt that is indirectly funded by net new funding provided by that ultimate funder, and the difference between the withholding tax rates on interest paid to that ultimate funder and on the actual interest paid by the taxpayer to the direct creditor A key difference from the existing rules is that under the amended 2

3 formula, funding provided by an ultimate funder who is entitled to the same or lower withholding tax rate on interest as the intermediary is incorporated into the calculation of the deemed interest (potentially reducing the deemed interest paid to other ultimate funders who are subject to higher withholding tax rates). This funding is ignored under the existing rules, which could result in higher overall withholding tax. When the total amount of incoming funding received by an intermediary exceeds the total amount of outgoing funding provided by that intermediary in respect of the taxpayer s debt, excess funding rules effectively reduce the amount of each incoming funding arrangement pro-rata, so that the total amounts of incoming funding and outgoing funding are equal. Similarly, when multiple Canadian debts are indirectly funded by the same incoming funding arrangement, this incoming funding is allocated between the Canadian debts pro-rata. See the Appendix for an example that illustrates key differences between the existing and amended rules in a situation involving multiple intermediaries. The back-to-back rules may deem a taxpayer to pay interest to many different ultimate funders. In these circumstances, the parties can elect for the deemed interest to instead be paid to a single designated ultimate funder, if the withholding tax on interest paid to the designated ultimate funder is not less than the tax that would be imposed on interest paid to any other electing ultimate funder. PwC observation This election, which was introduced in the October proposals, can mitigate the compliance burdens arising in situations with multiple ultimate funders (although it cannot reduce the overall tax payable). Character substitution The new character substitution rules prevent taxpayers from avoiding the back-to-back rules by substituting funding arrangements with economically similar arrangements involving an intermediary and a nonresident. They generally apply when an intermediary has an obligation to pay a dividend on shares, or to make a rent or royalty payment under a royalty arrangement, and either: the amount of the payment is determined by reference to an amount of interest paid under a funding arrangement, or there is a causal connection between the shares or royalty arrangement and the particular funding arrangement (similar to the causal connection test described above) When this test is met, the holding of the shares or the royalty arrangement generally is deemed to be a funding arrangement to which the back-toback loan rules will apply. In addition to these rules, certain shares with debt-like attributes (i.e. shares that are retractable by the holder) are deemed to be debt, which may be subject to the ordinary backto-back loan rules. Similar character substitution rules are also introduced as part of the back-to-back rent and royalty rules (discussed below). PwC observation The character substitution rules, as they relate to shares, are broader than recharacterizing shares with debt-like features (e.g. fixed value, redeemable and retractable preferred shares) and could apply to ordinary common shares if the causal connection test is met. Back-to-back rents and royalties The new back-to-back royalty rules are modelled on the back-to-back loan rules, and address similar arrangements involving rents, royalties and similar payments. The rules apply in certain circumstances when one or more ultimate licensors indirectly lease or license property to a Canadian taxpayer by way of a chain of relevant royalty arrangements involving one or more intermediaries. A relevant royalty arrangement can be a lease, license or similar agreement, an assignment, or an instalment sale. An ultimate licensor is essentially a person who ultimately provides property, i.e. leases or licenses property under a relevant royalty arrangement, and is not a lessee or licensee under another relevant royalty arrangement. The connection test that must be satisfied to link a chain of royalty arrangements is somewhat similar to the connection test in the back-toback loan rules. This test considers causal connections between incoming royalty arrangements received by an intermediary and outgoing royalty arrangements provided by an intermediary, as well as linkages based on the amounts paid under relevant royalty arrangements. When the licensor under an incoming royalty arrangement deals at arm s length with the taxpayer, the connection test will be satisfied only if one of the main purposes of this 3

4 arrangement is to reduce or avoid withholding tax, or to avoid the backto-back royalty rules. This additional condition was added in the October proposals, and is intended to prevent the rules from applying to ordinary, arm s length commercial transactions that are structured without any main tax purposes. However, it may be difficult to rely on this condition in practice, because a Canadian taxpayer is not likely to have sufficient information to determine an arm s length licensor s tax motivations. When the back-to-back royalty rules apply, the taxpayer is deemed to pay an amount to each ultimate licensor for purposes of the withholding tax rule for rents and royalties. The deemed amount has the same character as the actual payment by the taxpayer to the direct licensor. The amount paid to each ultimate licensor is equal to the actual amount paid by the taxpayer, adjusted to reflect: the portion of the actual payment that the taxpayer demonstrates is reasonably allocable to that ultimate licensor, and the difference between the withholding tax rates on a payment to that ultimate licensor and on the actual payment by the taxpayer. If the Minister does not accept that the taxpayer s allocation is reasonable, the amount paid to each ultimate licensor is equal to the actual amount paid by the taxpayer, adjusted to reflect: an equal allocation of the actual payment between all ultimate licensors, and the difference between the highest withholding tax rate imposed on a payment to any ultimate licensor and on the actual payment As mentioned, the back-to-back royalty rules are supported by character substitution rules, which apply in certain situations when equity or debt funding is substituted for a royalty arrangement. PwC observation The effect of the allocation formula, when the Minister does not accept the taxpayer s allocation as being reasonable, will be additional withholding taxes (due to the use of the highest withholding tax imposed on a payment to any ultimate licensor). This can be exacerbated by the fact that the formula does not recognize any spread between the royalties paid and received by an intermediary, which may reflect value added by the intermediary. As a result, taxpayers should ensure that their allocations are documented and reasonable in the circumstances. New shareholder loan rules The shareholder loan rules can apply when a taxpayer, who is a shareholder of a Canadian corporation (or who is connected with such a shareholder), receives a loan from the corporation (or a related corporation), and the loan is not repaid within one year from the end of the taxation year in which the loan is made. If the rules apply, the amount of the loan is included in the taxpayer s income and an offsetting deduction may be available when the loan is repaid. When the taxpayer is a non-resident, the income inclusion with respect to the loan is deemed to have been received by the non-resident as a dividend, and is subject to nonresident withholding tax. When the loan is repaid by the nonresident, a refund of the withholding tax remitted may be available to the non-resident if certain conditions are met and a refund application is timely filed by the non-resident. Related rules deem the taxpayer to receive a benefit to the extent that the interest on the loan is below a prescribed rate. If a Canadian corporation is a member of a foreign-controlled multinational group, a loan from the corporation to a non-resident group member can be exempted from the default shareholder loan rules, described above, by making a pertinent loan or indebtedness (PLOI) election. When this election is made, the Canadian corporation must recognize a minimum amount of interest income on the loan for Canadian income tax purposes. Bill C-29 introduces back-to-back rules for shareholder loans, which are similar to the back-to-back loan rules, discussed above. These rules generally address situations in which one or more ultimate funders indirectly provide funding to an intended borrower by way of a chain of funding arrangements involving one or more intermediaries, and the shareholder loan rules would apply to a direct loan from an ultimate funder to the intended borrower. In a typical scenario, the ultimate funder is a Canadian corporation and the intended borrower is a related non-resident. The required connection between the incoming funding received by an 4

5 intermediary and the outgoing funding provided by the intermediary is based on the same connection test as in the back-to-back loan rules for withholding tax, except that it excludes funding that is already subject to the shareholder loan rules (to prevent the same funding from being included in income twice) or on which a PLOI election has been filed. When the new rules apply, the intended borrower is deemed to receive a loan from each ultimate funder for purposes of the shareholder loan rules, to the extent that the intended borrower s debt is indirectly funded by the particular ultimate funder. All or a portion of a deemed loan may be deemed to be repaid when the amount of either the incoming funding to the intermediary or the outgoing funding provided by the intermediary is reduced, if the reduction is not part of a series of loans or other transactions and repayments. If, in the chain of funding arrangements, there: is only one intermediary the amendments apply to shareholder debts that are outstanding after March 21, 2016 (debts arising before March 22, 2016, are deemed to arise on March 22, 2016, for the purposes of these rules) are multiple intermediaries (i.e. the ultimate funder provides funding to the intended borrower through a funding chain with more than one intermediary) the amendments apply to shareholder debts that are outstanding after December 31, 2016 (debts arising before January 1, 2017, are deemed to arise on January 1, 2017, for the purposes of these rules) PwC observations The back-to-back shareholder loan rules could apply to deposits made by a Canadian company to a notional cash pool. Given the effective date of March 22, 2016 (except when there are multiple intermediaries), Canadian companies should review their participation in arrangements, such as notional cash pools, as soon as possible to determine if the new rules apply to them. If planning will be carried out to address the new rules (e.g., making distributions to repay loans), the tax provision implications of this planning should be considered. The takeaway Bill C-29 expands the existing rules for back-to-back loans into a broader back-to-back regime. The back-toback rules generally operate mechanically, based on factual connections between funding or royalty arrangements, instead of relying on purpose tests. As a result, the rules could apply to many ordinary business transactions that do not have tax avoidance purposes. The application of the back-to-back rules depends largely on factual determinations. Canadian taxpayers may face difficulties obtaining the information required to make these determinations, particularly in the context of arm s length arrangements. The back-to-back rules are complex, rely heavily on the use of defined terms and raise many interpretive issues. It is not yet clear how the Canada Revenue Agency will apply these rules in practice. The new rules therefore create significant uncertainty. Please consult your PwC tax adviser if you have specific questions regarding their application. 5

6 Appendix The following example illustrates key differences between the existing and amended rules in a situation involving multiple intermediaries. It involves a Canadian taxpayer (Canco) and four related non-residents (NR1, NR2, NR3 and NR4). Facts Loans (it is assumed that each loan satisfies the connection test in the back-to-back rules): Canco receives a $1,500 loan from NR1 NR1 receives a $2,000 loan from NR2 and a $1,000 loan from NR3 NR3 receives a $1,000 loan from NR4 Other facts: Canco pays $150 interest to NR1, which is subject to 10% withholding tax (or $15) due to a tax treaty Interest paid to NR4 is also eligible for a 10% treaty rate Interest paid to NR2 or NR3 is not eligible for treaty benefits (and is therefore subject to a 25% withholding tax rate) Existing rules Under the existing rules, Canco is deemed to pay interest to both NR2 and NR3, because they both provide funding to NR1, and interest paid to each funder would be subject to a higher withholding tax rate than interest paid to NR1 (notwithstanding that NR3 is itself funded by NR4, which is not subject to a higher tax rate). The total funding provided by NR2 and NR3 to NR1 ($3,000) exceeds the funding provided by NR1 to Canco ($1,500); Canco can reduce the allocations to NR2 and NR3 in a reasonable manner to eliminate this excess funding. The specific allocation between NR2 and NR3 is less relevant in this case, since both are subject to a 25% tax rate. The deemed interest is also adjusted to reflect the difference between the tax rates on interest paid to NR2 or NR3 (25%) and interest paid to NR1 (10%). Due to these adjustments, Canco is deemed to pay total interest of $90 to NR2 and NR3, which is subject to $22.50 tax. The total withholding tax remitted by Canco (including the withholding tax on actual interest paid to NR1) is $37.50, or the amount of withholding tax that would have applied had Canco paid its $150 of interest directly to NR 2 and NR 3. Amended rules Under the amended rules, NR2 and NR4 are both ultimate funders, because each provides net new funding (NR2 provides $2,000 and NR4 provides $1,000). NR1 and NR3 are not ultimate funders, because they do not provide net new funding; they merely pass-on funding received from NR2 and NR4. 6

7 Because NR1 receives $1,500 excess funding (see above), the amounts of funding received from NR2 and NR3 are reduced pro-rata (to $1,000 from NR2 and $500 from NR3) to eliminate the excess. Accordingly, the deemed interest paid to each ultimate funder is computed on the basis that Canco receives indirect funding of $1,000 from NR2 and $500 from NR4. The deemed interest is also adjusted to reflect the difference in tax rates on interest paid to each ultimate funder and interest paid to NR1. Canco is not deemed to pay any interest to NR4, because NR4 is eligible for the same 10% treaty rate as NR1. Canco is deemed to pay $60 interest to NR2, which is subject to $15 tax. The amended rules impose less overall tax, because they recognize that the funding provided by NR3 is ultimately funded by NR4. 7

8 Let s talk For a deeper discussion on what these measures mean for your business, please contact any of the following: Mike Maikawa mike.maikawa@pwc.com Leo Mitsiadis leo.mitsiadis@pwc.com Eric Labelle eric.labelle@pwc.com Jason Durkin jason.d.durkin@pwc.com This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisers PricewaterhouseCoopers LLP, an Ontario limited liability partnership. All rights reserved. PwC refers to the Canadian member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see for further details.

Canada Releases Revised Back-to-Back Loan Rules

Canada Releases Revised Back-to-Back Loan Rules Volume 76, Number 4 October 27, 2014 Canada Releases Revised Back-to-Back Loan Rules by Steve Suarez Reprinted from Tax Notes Int l, October 27, 2014, p. 357 Canada Releases Revised Back-to-Back Loan Rules

More information

Cross Border Tax Issues

Cross Border Tax Issues Cross Border Tax Issues By Reinhold G. Krahn December 2000 This is a general overview of the subject matter and should not be relied upon as legal advice or opinion. For specific legal advice on the information

More information

Comparing REITs. kpmg.ca

Comparing REITs. kpmg.ca Comparing REITs US vs. Canada January 2013 kpmg.ca Table of Contents REITs US & Canada Tax at Shareholders Level el US & Canada Corporate domestic shareholders Individual domestic shareholders Foreign

More information

Leveraged Life Insurance Personal Ownership

Leveraged Life Insurance Personal Ownership Leveraged Life Insurance Personal Ownership Introduction Leveraged life insurance is a financial planning strategy that uses the cash value of an exempt life insurance policy as collateral security for

More information

USA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax

USA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax USA Taxation FUNDS AND FUND MANAGEMENT 2010 3.1 Taxation of funds Taxation of regulated investment companies: income tax Investment companies in the United States (US) are structured either as openend

More information

International Taxation

International Taxation KPMG LLP Calgary Young Practitioners Group International Taxation I. Outbound Investment Overview & Update Foreign Affiliate / Controlled Foreign Affiliate PI Overview Surplus Overview October 24, 2012

More information

Corporate Taxation & Structuring in Canada and Canadian Scientific Research & Experimental Development Program Overview (SR&ED)

Corporate Taxation & Structuring in Canada and Canadian Scientific Research & Experimental Development Program Overview (SR&ED) Corporate Taxation & Structuring in Canada and Canadian Scientific Research & Experimental Development Program Overview (SR&ED) Claude E. Jodoin, M.Fisc. Maximize your R&D $...Look North of the border!

More information

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS LAWS AND DECREES The Income Tax (Amendment) Law of 2005 The Special Contribution for Defence (Amendment) Law of 2004 The Assessment and Collection

More information

How Canada Taxes Foreign Income

How Canada Taxes Foreign Income - 1 - How Canada Taxes Foreign Income (Summary) Purpose of the book The purpose of writing this book, entitled How Canada Taxes Foreign Income is particularly for the benefit of foreign tax lawyers, accountants,

More information

CANADIAN CORPORATE TAXATION. A General Guide January 31, 2011 TABLE OF CONTENTS INCORPORATION OF A BUSINESS 1 POTENTIAL ADVANTAGES OF INCORPORATION 1

CANADIAN CORPORATE TAXATION. A General Guide January 31, 2011 TABLE OF CONTENTS INCORPORATION OF A BUSINESS 1 POTENTIAL ADVANTAGES OF INCORPORATION 1 CANADIAN CORPORATE TAXATION A General Guide January 31, 2011 TABLE OF CONTENTS PART A PAGE INCORPORATION OF A BUSINESS 1 POTENTIAL ADVANTAGES OF INCORPORATION 1 POTENTIAL DISADVANTAGES OF INCORPORATION

More information

Global FS Tax Newsflash How do the proposed FATCA regulations impact Insurers?

Global FS Tax Newsflash How do the proposed FATCA regulations impact Insurers? Global FS Tax Newsflash How do the proposed FATCA regulations impact Insurers? February 20, 2012 How do the proposed FATCA regulations impact Insurers On February 8th, the highly anticipated proposed regulations

More information

Overview of Canadian taxation of life insurance policies. New tax legislation for life insurance policies. January 2015

Overview of Canadian taxation of life insurance policies. New tax legislation for life insurance policies. January 2015 January 2015 Overview of Canadian taxation of life insurance policies Life insurance plays an increasingly important role in financial planning due to the growing wealth of Canadians. Besides the traditional

More information

Structuring Entry into the Canadian Market: A Corporate Tax Primer

Structuring Entry into the Canadian Market: A Corporate Tax Primer Structuring Entry into the Canadian Market: A Corporate Tax Primer It is critical for non-residents to obtain proper Canadian legal advice respecting their long-term tax position before entering the Canadian

More information

Appendix 3. The metric

Appendix 3. The metric Appendix 3 A consistent and useful effective tax rate methodology to assess the global tax performance of multinationals in relation to Australian-linked business operations 1 The purpose of this paper

More information

ASPE AT A GLANCE Section 3856 Financial Instruments

ASPE AT A GLANCE Section 3856 Financial Instruments ASPE AT A GLANCE Section 3856 Financial Instruments December 2014 Section 3856 Financial Instruments Effective Date Fiscal years beginning on or after January 1, 2011 1 SCOPE Applies to all financial instruments

More information

THE TAX-FREE SAVINGS ACCOUNT

THE TAX-FREE SAVINGS ACCOUNT THE TAX-FREE SAVINGS ACCOUNT The 2008 federal budget introduced the Tax-Free Savings Account (TFSA) for individuals beginning in 2009. The TFSA allows you to set money aside without paying tax on the income

More information

Understanding the Tax Implications of Exchange-Traded Funds

Understanding the Tax Implications of Exchange-Traded Funds Understanding the Tax Implications of Exchange-Traded Funds 11/21/2003 1 Forward Barclays Global Investors Canada Limited (Barclays Canada) is pleased to present "Understanding the Tax Implications of

More information

IBA 2001 CANCUN COMMITTEE NP STRUCTURING INTERNATIONAL EQUITY COMPENSATION PLANS CASE STUDY

IBA 2001 CANCUN COMMITTEE NP STRUCTURING INTERNATIONAL EQUITY COMPENSATION PLANS CASE STUDY IBA 2001 CANCUN COMMITTEE NP STRUCTURING INTERNATIONAL EQUITY COMPENSATION PLANS CASE STUDY CANADIAN APPROACH BY ALAIN RANGER FASKEN MARTINEAU DuMOULIN LLP Stock Exchange Tower Suite 3400, P.O. Box 242

More information

tes for Guidance Taxes Consolidation Act 1997 Finance Act 2014 Edition - Part 13

tes for Guidance Taxes Consolidation Act 1997 Finance Act 2014 Edition - Part 13 Part 13 Close companies CHAPTER 1 Interpretation and general 430 Meaning of close company 431 Certain companies with quoted shares not to be close companies 432 Meaning of associated company and control

More information

Mexico Mergers and acquisitions involving Mexican assets

Mexico Mergers and acquisitions involving Mexican assets p84-88 IM&A - Chevez Rulz 21/03/2013 08:44 Page 84 Mexico Mergers and acquisitions involving Mexican assets by Ricardo Rendon and Layda Carcamo, Chevez, Ruiz, Zamarripa y Cia, S.C. Whenever a corporate

More information

GLOBAL GUIDE TO M&A TAX

GLOBAL GUIDE TO M&A TAX Quality tax advice, globally GLOBAL GUIDE TO M&A TAX 2013 EDITION www.taxand.com CYPRUS Cyprus From a Buyer s Perspective 1. What are the main differences among acquisitions made through a share deal versus

More information

United States Tax Alert

United States Tax Alert ba International Tax United States Tax Alert Contacts Jeff O Donnell jodonnell@deloitte.com Paul Crispino pcrispino@deloitte.com Jamie Dahlberg jdahlberg@deloitte.com Irwin Panitch ipanitch@deloitte.com

More information

TAX CONSIDERATIONS IN REAL ESTATE TRANSACTIONS. Investment by Foreign Persons in U.S. Real Estate

TAX CONSIDERATIONS IN REAL ESTATE TRANSACTIONS. Investment by Foreign Persons in U.S. Real Estate TAX CONSIDERATIONS IN REAL ESTATE TRANSACTIONS Investment by Foreign Persons in U.S. Real Estate Keith R. Gercken Pillsbury Winthrop LLP San Francisco, California Overview U.S. taxation of foreign persons

More information

TURKEY CORPORATE TAX (KURUMLAR VERGISI) The basic rate of corporation tax for resident and non-resident companies in Turkey is 20%.

TURKEY CORPORATE TAX (KURUMLAR VERGISI) The basic rate of corporation tax for resident and non-resident companies in Turkey is 20%. TURKEY CORPORATE TAX (KURUMLAR VERGISI) The basic rate of corporation tax for resident and non-resident companies in Turkey is 20%. Corporations in Turkey can be regarded as either limited or unlimited

More information

Are Your Tax-Free Inter-Corporate Dividends in Jeopardy?

Are Your Tax-Free Inter-Corporate Dividends in Jeopardy? Are Your Tax-Free Inter-Corporate Dividends in Jeopardy? May 27, 2015 No. 2015-23 Canadian corporations that receive dividends from other Canadian corporations may be adversely affected by a recently expanded

More information

Employee Life and Health Trust Explanatory Notes

Employee Life and Health Trust Explanatory Notes Employee Life and Health Trust Explanatory Notes 6(1)(a) Paragraph 6(1)(a) of the Income Tax Act (the Act) provides for the inclusion in computing the income of a taxpayer from an office or employment

More information

Debt Restructuring. 17th Taxation of Corporate Reorganization Conference January 22, 23 & 24, 2013 Kathleen S.M. Hanly and Kevin H.

Debt Restructuring. 17th Taxation of Corporate Reorganization Conference January 22, 23 & 24, 2013 Kathleen S.M. Hanly and Kevin H. Debt Restructuring 17th Taxation of Corporate Reorganization Conference January 22, 23 & 24, 2013 Kathleen S.M. Hanly and Kevin H. Yip Debt Restructuring Legislative framework for insolvency proceedings

More information

FACTORING AND FINANCING IN CANADA WHAT EVERY U.S. FACTOR AND LAWYER WANTS TO KNOW ABOUT PURCHASING AND TAKING SECURITY ON CANADIAN RECEIVABLES

FACTORING AND FINANCING IN CANADA WHAT EVERY U.S. FACTOR AND LAWYER WANTS TO KNOW ABOUT PURCHASING AND TAKING SECURITY ON CANADIAN RECEIVABLES FACTORING AND FINANCING IN CANADA WHAT EVERY U.S. FACTOR AND LAWYER WANTS TO KNOW ABOUT PURCHASING AND TAKING SECURITY ON CANADIAN RECEIVABLES Cross-border transactions involving U.S. and Canadian parties

More information

FIRSTSERVICE CORPORATION NOTICE OF REDEMPTION & CONVERSION TO ALL REGISTERED HOLDERS OF OUTSTANDING 7% CUMULATIVE PREFERENCE SHARES, SERIES 1

FIRSTSERVICE CORPORATION NOTICE OF REDEMPTION & CONVERSION TO ALL REGISTERED HOLDERS OF OUTSTANDING 7% CUMULATIVE PREFERENCE SHARES, SERIES 1 FIRSTSERVICE CORPORATION NOTICE OF REDEMPTION & CONVERSION TO ALL REGISTERED HOLDERS OF OUTSTANDING 7% CUMULATIVE PREFERENCE SHARES, SERIES 1 To: All Registered Holders of Outstanding 7% Cumulative Preference

More information

FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS

FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS Chapter 10 FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS Daniel Cassidy 1 10.1 INTRODUCTION Foreign companies with U.S. business transactions face various layers of taxation. These include income, sales,

More information

TAX 101 INTRODUCTORY LESSONS: FINANCING A U.S. SU BSIDIARY DEBT VS. EQUITY INTRODUCTION. Authors Galia Antebi and Nina Krauthamer

TAX 101 INTRODUCTORY LESSONS: FINANCING A U.S. SU BSIDIARY DEBT VS. EQUITY INTRODUCTION. Authors Galia Antebi and Nina Krauthamer TAX 101 INTRODUCTORY LESSONS: FINANCING A U.S. SU BSIDIARY DEBT VS. EQUITY Authors Galia Antebi and Nina Krauthamer Tags Debt Equity INTRODUCTION When a foreign business contemplates operating in the U.S.

More information

Assurance and accounting A Guide to Financial Instruments for Private

Assurance and accounting A Guide to Financial Instruments for Private june 2011 www.bdo.ca Assurance and accounting A Guide to Financial Instruments for Private Enterprises and Private Sector t-for-profit Organizations For many entities adopting the Accounting Standards

More information

NORTHERN BLIZZARD RESOURCES INC. STOCK DIVIDEND PROGRAM

NORTHERN BLIZZARD RESOURCES INC. STOCK DIVIDEND PROGRAM NORTHERN BLIZZARD RESOURCES INC. STOCK DIVIDEND PROGRAM Introduction This Stock Dividend Program (the "Program") provides eligible holders ("Shareholders") of common shares ("Common Shares") of Northern

More information

Tax Court Lowers Canco s AR Factoring Transfer Price

Tax Court Lowers Canco s AR Factoring Transfer Price Tax Court Lowers Canco s AR Factoring Transfer Price January 20, 2014 No. 2014-02 Canadian multinational companies may want to note the implications of the recent transfer pricing case McKesson Canada

More information

The Bank of Nova Scotia Shareholder Dividend and Share Purchase Plan

The Bank of Nova Scotia Shareholder Dividend and Share Purchase Plan The Bank of Nova Scotia Shareholder Dividend and Share Purchase Plan Offering Circular Effective November 6, 2013 The description contained in this Offering Circular of the Canadian and U.S. income tax

More information

Short Form Prospectus New Issue May 9, 2013

Short Form Prospectus New Issue May 9, 2013 No securities regulatory authority has expressed an opinion about these securities and it is an offence to claim otherwise. The securities have not been and will not be registered under the United States

More information

NOTICE TO INVESTORS: THE NOTES ARE SIGNIFICANTLY RISKIER THAN CONVENTIONAL DEBT INSTRUMENTS.

NOTICE TO INVESTORS: THE NOTES ARE SIGNIFICANTLY RISKIER THAN CONVENTIONAL DEBT INSTRUMENTS. PRICING SUPPLEMENT Filed Pursuant to Rule 424(b)(2) Registration Statement No. 333-171806 Dated May 22, 2013 Royal Bank of Canada Airbag Autocallable Yield Optimization Notes $6,732,000 Notes Linked to

More information

THE INTERNATIONAL FINANCE COMPANIES

THE INTERNATIONAL FINANCE COMPANIES INTERNATIONAL FINANCE COMPANIES (INCOME TAX THE INTERNATIONAL FINANCE COMPANIES (INCOME TAX ACT [lst January, 1971.I Ads 1 of 1971, 22 of 1975. 1. This Act may be cited as the International Finance Shorttitle

More information

MALTA: A JURISDICTION OF CHOICE

MALTA: A JURISDICTION OF CHOICE MALTA: A JURISDICTION OF CHOICE LONDON - September 2012 Doing business from Malta can make a huge difference for your business UHY BUSINESS ADVISORY SERVICES LIMITED Updated September, 2012 An attractive

More information

- 1 - Finance Act 2008 changes to the Capital Gains Tax charge on beneficiaries of non-resident settlements. Contents.

- 1 - Finance Act 2008 changes to the Capital Gains Tax charge on beneficiaries of non-resident settlements. Contents. Finance Act 2008 changes to the Capital Gains Tax charge on beneficiaries of non-resident settlements Contents Introduction 1 5 Section 87 from 6 April 2008 6 13 Matching capital payments with section

More information

Income Tax Issues in the Purchase and Sale of Assets. Catherine A. Brayley

Income Tax Issues in the Purchase and Sale of Assets. Catherine A. Brayley Income Tax Issues in the Purchase and Sale of Assets Catherine A. Brayley Income Tax Issues in the Purchase and Sale of Assets Catherine A. Brayley Bennett Jones LLP (Toronto) Table of Contents Scope of

More information

ACCOUNTING STANDARDS BOARD DECEMBER 1999 FRS 16 STANDARD FINANCIAL REPORTING ACCOUNTING STANDARDS BOARD

ACCOUNTING STANDARDS BOARD DECEMBER 1999 FRS 16 STANDARD FINANCIAL REPORTING ACCOUNTING STANDARDS BOARD ACCOUNTING STANDARDS BOARD DECEMBER 1999 FRS 16 16 CURRENT TAX FINANCIAL REPORTING STANDARD ACCOUNTING STANDARDS BOARD Financial Reporting Standard 16 Current Tax is issued by the Accounting Standards

More information

Avoiding U.S. Investment Tax Traps

Avoiding U.S. Investment Tax Traps Avoiding U.S. Investment Tax Traps Structuring Real Estate and Other Fund Investments Presented by: Joseph Gulant and Daniel Blickman Major Categories of Tax to Consider in Planning International Transactions

More information

Provinces and territories also impose income taxes on individuals in addition to federal taxes

Provinces and territories also impose income taxes on individuals in addition to federal taxes Worldwide personal tax guide 2013 2014 Canada Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Canada Revenue Agency (CRA)

More information

Article 1. Paragraph 3 of Article IV Dual resident companies

Article 1. Paragraph 3 of Article IV Dual resident companies DEPARTMENT OF THE TREASURY TECHNICAL EXPLANATION OF THE PROTOCOL DONE AT CHELSEA ON SEPTEMBER 21, 2007 AMENDING THE CONVENTION BETWEEN THE UNITED STATES OF AMERICA AND CANADA WITH RESPECT TO TAXES ON INCOME

More information

A QUICK GUIDE TO DIVIDENDS TAX

A QUICK GUIDE TO DIVIDENDS TAX A QUICK GUIDE TO DIVIDENDS TAX i A QUICK GUIDE TO DIVIDENDS TAX 1. INTRODUCTION TO DIVIDENDS TAX In 2007, the Minister of Finance announced that Secondary Tax on Companies (STC) would be replaced by Dividends

More information

TAX LAW / INVESTMENT FUNDS BULLETIN CANADA EXTENDS SOURCE TAXATION FOR INVESTMENT FUNDS

TAX LAW / INVESTMENT FUNDS BULLETIN CANADA EXTENDS SOURCE TAXATION FOR INVESTMENT FUNDS February 9, 2005 CANADA EXTENDS SOURCE TAXATION TAX LAW / INVESTMENT FUNDS BULLETIN The Department of Finance released on December 6, 2004, draft legislation (the Amendments ) implementing the March 23,

More information

Fall Tax Update. By: Ian Crosbie, Elie Roth, Raj Juneja, Nathan Boidman, Brian Bloom, Michael Kandev and Christopher Anderson

Fall Tax Update. By: Ian Crosbie, Elie Roth, Raj Juneja, Nathan Boidman, Brian Bloom, Michael Kandev and Christopher Anderson Davies Ward Phillips & Vineberg LLP November 7, 2012 Fall Tax Update By: Ian Crosbie, Elie Roth, Raj Juneja, Nathan Boidman, Brian Bloom, Michael Kandev and Christopher Anderson The month of October saw

More information

Related parties debt remission

Related parties debt remission Issue 3/2015 Related parties debt remission Related parties debt remission Inland Revenue has released an Officials Issues Paper seeking feedback on proposed legislative changes intended to make the debt

More information

[9.2.5] Capital Allowances for Intangible Assets under section 291A of the Taxes Consolidation Act 1997

[9.2.5] Capital Allowances for Intangible Assets under section 291A of the Taxes Consolidation Act 1997 [9.2.5] Capital Allowances for Intangible Assets under section 291A of the Taxes Consolidation Act 1997 Last updated July 2015 1. Introduction Capital allowances for expenditure incurred on intangible

More information

NAS 09 NEPAL ACCOUNTING STANDARDS ON INCOME TAXES

NAS 09 NEPAL ACCOUNTING STANDARDS ON INCOME TAXES NAS 09 NEPAL ACCOUNTING STANDARDS ON INCOME TAXES CONTENTS Paragraphs OBJECTIVE SCOPE 1-4 DEFINITIONS 5-11 Tax Base 7-11 RECOGNITION OF CURRENT TAX LIABILITIES AND CURRENT TAX ASSETS 12-14 RECOGNITION

More information

[LOGO] ROGERS COMMUNICATIONS INC. DIVIDEND REINVESTMENT PLAN. November 1, 2010

[LOGO] ROGERS COMMUNICATIONS INC. DIVIDEND REINVESTMENT PLAN. November 1, 2010 [LOGO] ROGERS COMMUNICATIONS INC. DIVIDEND REINVESTMENT PLAN November 1, 2010 Rogers Communications Inc. Dividend Reinvestment Plan Table of Contents SUMMARY... 3 DEFINITIONS... 4 ELIGIBILITY... 6 ENROLLMENT...

More information

Foreign Person Investing in U.S. Real Estate

Foreign Person Investing in U.S. Real Estate Foreign Person Investing in U.S. Real Estate Ian Shane Golenbock Eiseman Assor Bell & Peskoe LLP TTN New York Conference 2013 Foreign Purchases of U.S. Homes Foreign Home Buyers want to: Minimize tax on

More information

New Zealand. Country M&A Team Country Leader ~ Peter Boyce Declan Mordaunt Mike Morgan Eleanor Ward Ian Fay Michelle Redington Ravi Mehta

New Zealand. Country M&A Team Country Leader ~ Peter Boyce Declan Mordaunt Mike Morgan Eleanor Ward Ian Fay Michelle Redington Ravi Mehta New Zealand Country M&A Team Country Leader ~ Peter Boyce Declan Mordaunt Mike Morgan Eleanor Ward Ian Fay Michelle Redington Ravi Mehta Mergers & Acquisitions Asian Taxation Guide 2008 New Zealand March

More information

International Financial Reporting Standards (IFRS)

International Financial Reporting Standards (IFRS) FACT SHEET September 2011 IAS 7 Statement of Cash Flows (This fact sheet is based on the standard as at 1 January 2010.) Important note: This fact sheet is based on the requirements of the International

More information

A PRIMER ON THE HISTORIC REHABILITATION TAX CREDIT

A PRIMER ON THE HISTORIC REHABILITATION TAX CREDIT COMBINING HISTORIC PRESERVATION AND BROWNFIELD DEVELOPMENT INCENTIVES AND TAX CREDITS: CASE STUDIES IN CREATIVE DEAL MAKING A PRIMER ON THE HISTORIC REHABILITATION TAX CREDIT John H. Gadon Lane Powell

More information

Treatment of Hybrid Entities. 5th Taxation of Inbound Investment Course September 19 & 20, 2011 Kathleen S.M. Hanly and Kevin H.

Treatment of Hybrid Entities. 5th Taxation of Inbound Investment Course September 19 & 20, 2011 Kathleen S.M. Hanly and Kevin H. Treatment of Hybrid Entities 5th Taxation of Inbound Investment Course September 19 & 20, 2011 Kathleen S.M. Hanly and Kevin H. Yip Topics Concepts: Fiscally transparent entity Hybrid entity Art. IV:6

More information

Investment into Canada

Investment into Canada Asia Pacific International Core of Excellence Investment into Canada Chris Roberge Deloitte AP ICE - Canada Vanessa Poon Deloitte AP ICE Canada June 6, 2012 Agenda Canadian tax regime overview Introduction

More information

Monaco Corporate Taxation

Monaco Corporate Taxation Introduction Monaco is a sovereign principality. France is a guarantor of the sovereignty and territorial integrity of Monaco, while Monaco is to conform to French interests. Although the Prince is the

More information

COMMENTARIES ON THE ARTICLES OF THE MODEL TAX CONVENTION

COMMENTARIES ON THE ARTICLES OF THE MODEL TAX CONVENTION COMMENTARIES ON THE ARTICLES OF THE MODEL TAX CONVENTION COMMENTARY ON ARTICLE 1 CONCERNING THE PERSONS COVERED BY THE CONVENTION 1. Whereas the earliest conventions in general were applicable to citizens

More information

Income in the Netherlands is categorised into boxes. The above table relates to Box 1 income.

Income in the Netherlands is categorised into boxes. The above table relates to Box 1 income. Worldwide personal tax guide 2013 2014 The Netherlands Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Belastingdienst www.belastingdienst.nl

More information

Company tax return 2015

Company tax return 2015 Company tax return 2015 Day Month Year Day Month Year to Or specify period if part year or approved substitute period tes to help you prepare this tax return are in the Company tax return instructions

More information

deduction, as well as any additional relief provided for in any applicable tax treaty between Canada and the other country.

deduction, as well as any additional relief provided for in any applicable tax treaty between Canada and the other country. TAX NEWSLETTER Special Release: August 2008 REAL OPPORTUNITY: CANADIANS & U.S. REAL ESTATE The weak U.S. economy, the recent subprime mortgage crisis and the strength of the Canadian dollar relative to

More information

The Lifetime Capital Gains Exemption

The Lifetime Capital Gains Exemption The Lifetime Capital Gains Exemption Introduction This Tax Topic briefly reviews the rules contained in section 110.6 of the Income Tax Act (the "Act") concerning the lifetime capital gains exemption and

More information

TAX ASPECTS OF MUTUAL FUND INVESTING

TAX ASPECTS OF MUTUAL FUND INVESTING Tax Guide for 2015 TAX ASPECTS OF MUTUAL FUND INVESTING INTRODUCTION I. Mutual Fund Distributions A. Distributions From All Mutual Funds 1. Net Investment Income and Short-Term Capital Gain Distributions

More information

EFFECTIVE INTERNATIONAL INTELLECTUAL PROPERTY STRATEGIES TO MITIGATE U.S. TAXES

EFFECTIVE INTERNATIONAL INTELLECTUAL PROPERTY STRATEGIES TO MITIGATE U.S. TAXES EFFECTIVE INTERNATIONAL INTELLECTUAL PROPERTY STRATEGIES TO MITIGATE U.S. TAXES DENNIS S. FERNANDEZ INNA S. SHESTUL Fernandez & Associates, L.L.P. Fernandez & Associates, L.L.P. 1047 El Camino Real, Ste

More information

The authors wish to acknowledge the contributions of Jared Mackey of Bennett Jones LLP in the preparation of this paper.

The authors wish to acknowledge the contributions of Jared Mackey of Bennett Jones LLP in the preparation of this paper. CANADIAN PETROLEUM TAX JOURNAL Vol. 26, 2013-5 Forming U.S. Master Limited Partnerships with Canadian Assets: A U.S. and Canadian Tax Perspective Greg Johnson, Bennett Jones LLP (Calgary), and Tim Devetski,

More information

450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005

450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005 Eric van Aalst Mark Riedy Citco Corporate Services Inc. Andrews Kurth LLP 450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005 Structuring International Operations

More information

Accountant s Tax Guide

Accountant s Tax Guide Accountant s Tax Guide For the year ended 30 June 2010 Macquarie Wrap Macquarie Adviser Services Tax policies and general assumptions The purpose of the Accountants Tax Guide (the Guide) is to provide

More information

Model S Corporation Income Tax Act

Model S Corporation Income Tax Act American Bar Association Section of Taxation Committee on S Corporations Subcommittee on the State Taxation of S Corporations June 1989 (Revised) Model S Corporation Income Tax Act Recommended (with Six

More information

IPSAS 2 CASH FLOW STATEMENTS

IPSAS 2 CASH FLOW STATEMENTS IPSAS 2 CASH FLOW STATEMENTS Acknowledgment This International Public Sector Accounting Standard (IPSAS) is drawn primarily from International Accounting Standard (IAS) 7, Cash Flow Statements published

More information

THIN CAPITALISATION LEGISLATION. A BACKGROUND PAPER FOR COUNTRY TAX ADMINISTRATIONS (Pilot version for comments)

THIN CAPITALISATION LEGISLATION. A BACKGROUND PAPER FOR COUNTRY TAX ADMINISTRATIONS (Pilot version for comments) THIN CAPITALISATION LEGISLATION A BACKGROUND PAPER FOR COUNTRY TAX ADMINISTRATIONS (Pilot version for comments) Initial draft - August 2012 1 THIN CAPITALISATION Introduction This paper, which has been

More information

The Benefits of Using an Unlimited Liability Company

The Benefits of Using an Unlimited Liability Company The Benefits of Using an Unlimited Liability Company By Leonard Glass April 29, 2005 The first version of this paper was presented to the Taxation Subsection of the B.C. Branch of the Canadian Bar Association

More information

U.S. TAX ISSUES FOR CANADIANS

U.S. TAX ISSUES FOR CANADIANS March 2015 CONTENTS Snowbirds Canadians owning U.S. rental properties Summary U.S. TAX ISSUES FOR CANADIANS If you own rental property in the United States or spend extended periods of time there, you

More information

Invesco s guide to your tax statement

Invesco s guide to your tax statement Invesco s guide to your tax statement June 2016 This guide has been prepared by Invesco to assist you in completing your income tax return for the year ended 30 June 2016. This guide relates only to your

More information

Sri Lanka Accounting Standard-LKAS 7. Statement of Cash Flows

Sri Lanka Accounting Standard-LKAS 7. Statement of Cash Flows Sri Lanka Accounting Standard-LKAS 7 Statement of Cash Flows CONTENTS SRI LANKA ACCOUNTING STANDARD-LKAS 7 STATEMENT OF CASH FLOWS paragraphs OBJECTIVE SCOPE 1 3 BENEFITS OF CASH FLOW INFORMATION 4 5 DEFINITIONS

More information

www.pwc.com U.S. Legislative Outlook Tom Patten 2 March 2011

www.pwc.com U.S. Legislative Outlook Tom Patten 2 March 2011 www.pwc.com U.S. Legislative Outlook Tom Patten 2 Agenda Understanding the U.S. legislative process. Recent legislative developments. Proposals. 2 Understanding the U.S. Legislative Process The Long Road

More information

TREATY ENTITLEMENT OF NON-CIV FUNDS

TREATY ENTITLEMENT OF NON-CIV FUNDS TREATY ENTITLEMENT OF NON-CIV FUNDS 24 March 2016 BEPS CONSULTATION DOCUMENT ON THE TREATY ENTITLEMENT OF NON-CIV FUNDS Paragraph 14 of the final version of the report on Action 6 Preventing the Granting

More information

Canadian Corporate Tax Guide

Canadian Corporate Tax Guide Canadian Corporate Tax Guide P850 Goodmans Tax Guide Cover:P850 Goodmans Tax Guide Cover 10-01-14 5:21 PM Page 2 Canadian Corporate Tax Guide About This Guide If you are considering doing business in Canada,

More information

CYPRUS TAX CONSIDERATIONS

CYPRUS TAX CONSIDERATIONS TAXATION The following summary of material Cyprus, US federal income and United Kingdom tax consequences of ownership of the GDRs is based upon laws, regulations, decrees, rulings, income tax conventions

More information

Deloitte GAAP 2014: FRS 102 - Volume B (UK Series)

Deloitte GAAP 2014: FRS 102 - Volume B (UK Series) Deloitte GAAP 2014: UK Reporting - FRS 102 - Volume B (UK Series) Chapter B7: Free postage when you order online www.lexisnexis.co.uk/store or call 0845 370 1234 B7 Contents 1 Introduction 211 2 Scope

More information

Daily Income Fund Retail Class Shares ( Retail Shares )

Daily Income Fund Retail Class Shares ( Retail Shares ) Daily Income Fund Retail Class Shares ( Retail Shares ) Money Market Portfolio Ticker Symbol: DRTXX U.S. Treasury Portfolio No Ticker Symbol U.S. Government Portfolio Ticker Symbol: DREXX Municipal Portfolio

More information

RioCan Real Estate Investment Trust

RioCan Real Estate Investment Trust RioCan Real Estate Investment Trust Offering Circular describing the terms for a Unitholder Distribution Reinvestment Plan and Unit Purchase Plan RIOCAN REAL ESTATE INVESTMENT TRUST Unitholder Distribution

More information

Indian Accounting Standard (Ind AS) 7 Statement of Cash Flows

Indian Accounting Standard (Ind AS) 7 Statement of Cash Flows Contents Indian Accounting Standard (Ind AS) 7 Statement of Cash Flows Paragraphs OBJECTIVE SCOPE 1 3 BENEFITS OF CASH FLOW INFORMATION 4 5 DEFINITIONS 6 9 Cash and cash equivalents 7 9 PRESENTATION OF

More information

Notice 97-34, 1997-1 CB 422, 6/02/1997, IRC Sec(s). 6048

Notice 97-34, 1997-1 CB 422, 6/02/1997, IRC Sec(s). 6048 Notice 97-34, 1997-1 CB 422, 6/02/1997, IRC Sec(s). 6048 Returns of foreign trusts foreign gift reporting requirements tax This notice provides guidance regarding the new foreign trust and foreign gift

More information

AND IN THE MATTER OF THE MUTUAL RELIANCE REVIEW SYSTEM FOR EXEMPTIVE RELIEF APPLICATIONS AND IN THE MATTER OF SNC-LAVALIN GROUP INC.

AND IN THE MATTER OF THE MUTUAL RELIANCE REVIEW SYSTEM FOR EXEMPTIVE RELIEF APPLICATIONS AND IN THE MATTER OF SNC-LAVALIN GROUP INC. IN THE MATTER OF THE SECURITIES LEGISLATION OF BRITISH COLUMBIA, ALBERTA, SASKATCHEWAN, MANITOBA, ONTARIO, QUÉBEC, NEWFOUNDLAND AND LABRADOR AND NOVA SCOTIA AND IN THE MATTER OF THE MUTUAL RELIANCE REVIEW

More information

Daily Income Fund Retail Class Shares ( Retail Shares )

Daily Income Fund Retail Class Shares ( Retail Shares ) Daily Income Fund Retail Class Shares ( Retail Shares ) Money Market Portfolio Ticker Symbol: DRTXX U.S. Treasury Portfolio No Ticker Symbol U.S. Government Portfolio Ticker Symbol: DREXX Municipal Portfolio

More information

SMALL BUSINESS INVESTMENT ACT OF 1958. This Act may be cited as the Small Business Investment Act of 1958.

SMALL BUSINESS INVESTMENT ACT OF 1958. This Act may be cited as the Small Business Investment Act of 1958. This compilation includes P.L. 110-246, enacted 6/18/08. SMALL BUSINESS INVESTMENT ACT OF 1958 (Public Law 85-699, as amended) Sec. 101. SHORT TITLE This Act may be cited as the Small Business Investment

More information

Vertex Wealth Management LLC

Vertex Wealth Management LLC Vertex Wealth Management LLC Michael Aluotto President Private Wealth Manager 1325 Franklin Ave., Ste. 335 Garden City, NY 11530 516-294-8200 mjaluotto@1stallied.com S Corporation Page 1 of 7, see disclaimer

More information

Foreign Investment in Real Property Tax Act 1980 Buyer AND Seller Beware. By R. Scott Jones, Esq.

Foreign Investment in Real Property Tax Act 1980 Buyer AND Seller Beware. By R. Scott Jones, Esq. Foreign Investment in Real Property Tax Act 1980 Buyer AND Seller Beware By R. Scott Jones, Esq. This article summarizes the tax withholding rules imposed on a buyer and his/her agent when purchasing U.S.

More information

For the year ended 31 March 2015. Guide to year end tax planning

For the year ended 31 March 2015. Guide to year end tax planning For the year ended 31 March 2015 Guide to year end tax planning Contents Introduction Year end tax planning checklist 5 Current income tax rates 9 Provisional tax overview 11 Penalties regime 13 Record

More information

MIDDLEFIELD RESOURCE FUNDS. Understanding Tax Advantaged Investments

MIDDLEFIELD RESOURCE FUNDS. Understanding Tax Advantaged Investments MIDDLEFIELD RESOURCE FUNDS Understanding Tax Advantaged Investments Middlefield Group profile Since its inception in 1979, the Middlefield Group, with over $3.0 billion in assets under management, has

More information

INCOME TAX CONSIDERATIONS IN SHAREHOLDERS' AGREEMENTS

INCOME TAX CONSIDERATIONS IN SHAREHOLDERS' AGREEMENTS INCOME TAX CONSIDERATIONS IN SHAREHOLDERS' AGREEMENTS Evelyn R. Schusheim, B.A., LL.B., LL.M. 2010 Tax Law for Lawyers Canadian Bar Association The Queen s Landing Inn Niagara-on-the-Lake, Ontario OVERVIEW

More information

Payments subject to withholding tax Generally, a person has to withhold tax when he makes payments of the following nature to a non-resident person:

Payments subject to withholding tax Generally, a person has to withhold tax when he makes payments of the following nature to a non-resident person: RELEVANT TO ACCA QUALIFICATION PAPER F6 (SGP) Understanding withholding tax rules in Singapore In a nutshell, withholding tax is an efficient mechanism to collect corporate income tax from certain groups

More information

NEPAL ACCOUNTING STANDARDS ON CASH FLOW STATEMENTS

NEPAL ACCOUNTING STANDARDS ON CASH FLOW STATEMENTS NAS 03 NEPAL ACCOUNTING STANDARDS ON CASH FLOW STATEMENTS CONTENTS Paragraphs OBJECTIVE SCOPE 1-3 BENEFITS OF CASH FLOWS INFORMATION 4-5 DEFINITIONS 6-9 Cash and cash equivalents 7-9 PRESENTATION OF A

More information

Partner's Instructions for Schedule K-1 (Form 1065)

Partner's Instructions for Schedule K-1 (Form 1065) 2014 Partner's Instructions for Schedule K-1 (Form 1065) Partner's Share of Income, Deductions, Credits, etc. (For Partner's Use Only) Department of the Treasury Internal Revenue Service Section references

More information