On February 27, 2025, FinCEN confirmed that it would halt enforcement actions in relation to the Corporate Transparency Act (“CTA”) while it developed revised regulations that would prioritize reporting for “those entities...more
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 January 1, 2024, new direct reporting requirements to the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of the Treasury, became effective – known as the Corporate Transparency...more
1/31/2024
/ Beneficial Owner ,
Business Entities ,
Canada ,
Corporate Issuers ,
Corporate Transparency Act ,
Effective Date ,
Exemptions ,
Filing Deadlines ,
FinCEN ,
Foreign Issuers ,
Form 10-K ,
NYSE ,
Reporting Requirements ,
Securities Exchange Act ,
Subsidiaries
Canadian persons and entities owning a significant interest in a U.S. corporation or U.S. entity classified as a “disregarded entity” for U.S. federal income tax purposes should ensure they are compliant with IRS Form 5472...more
An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden.
The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more
2/3/2021
/ FATCA ,
Financial Institutions ,
Foreign Financial Accounts ,
Foreign Investment ,
Gross Proceeds ,
IRS ,
Offshore Funds ,
Proposed Legislation ,
Reporting Requirements ,
Tax Evasion ,
Tax Planning ,
U.S. Treasury ,
Withholding Requirements