Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more
1/31/2025
/ Canada ,
Corporate Counsel ,
Corporate Taxes ,
Dividends ,
Foreign Corporations ,
Internal Revenue Code (IRC) ,
IRS ,
Reporting Requirements ,
Tax Credits ,
Tax Planning ,
Taxation ,
Withholding Requirements
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
8/23/2022
/ Biden Administration ,
Canada ,
Corporate Taxes ,
Covered Entities ,
Domestic Corporations ,
Excise Tax ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
IRS ,
Publicly-Traded Companies ,
Share Buybacks ,
Stock Repurchases ,
U.S. Treasury
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...more
8/23/2022
/ Biden Administration ,
Corporate Taxes ,
Covered Entities ,
Domestic Corporations ,
Excise Tax ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
IRS ,
Publicly-Traded Companies ,
Share Buybacks ,
Stock Repurchases ,
U.S. Treasury
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
Generally, an “inversion” is a transaction in which a non-U.S. corporation directly or indirectly acquires substantially all of the properties held by a U.S. corporation or partnership, after which the former owners of that...more
The CARES Act, signed into law on March 27, 2020 in the wake of the onset of the Covid-19 pandemic, contained numerous changes to U.S. federal income tax law. One such change applied to the deductibility of net operating...more
The federal Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act” or the “Act”), signed into law on March 27, 2020, contains significant (and mostly temporary) changes to federal tax law that provide immediate...more