On November 26, 2021, the Supreme Court of Canada (the SCC) released its highly anticipated decision in Canada v Alta Energy Luxembourg SARL, 2021 SCC 49 [Alta Energy Lux], that addressed treaty-based holding structures and...more
On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more
5/31/2019
/ Anti-Avoidance ,
BEPS ,
Canada ,
Capital Gains ,
Energy Sector ,
Foreign Investment ,
International Tax Issues ,
OECD ,
Private Equity Firms ,
Tax Treaty ,
Withholding Tax
Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures contained in the...more
4/4/2019
/ Anti-Avoidance ,
Capital Gains ,
Foreign Investment ,
International Tax Issues ,
Multilateral Agreement ,
OECD ,
Principal Purpose Test ,
Private Equity Firms ,
Ratification ,
Tax Agreements ,
Tax Treaty
The 2019 Canadian federal budget was released on March 19, 2019 (Budget Day). As many of the proposals are aimed at investing in Canada’s middle class, the Budget was relatively light on proposals affecting businesses....more
3/25/2019
/ BEPS ,
Canada ,
Corporate Taxes ,
Cross-Border Transactions ,
Federal Budget ,
Foreign Affiliates ,
Mutual Funds ,
Privately Held Corporations ,
Proposed Amendments ,
Tax Avoidance ,
Tax Treaty