On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more
2/27/2020
/ Anti-Avoidance ,
Capital Gains ,
Corporate Taxes ,
GAAR ,
Income Taxes ,
International Tax Issues ,
OECD ,
Principal Purpose Test ,
Private Equity Firms ,
Tax Treaty ,
Withholding Tax
On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). As noted in our...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