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
In our blog post dated August 22, 2022, we discussed the one percent (1%) excise tax on certain stock repurchase transactions by certain publicly traded corporations enacted as part of the Inflation Reduction Act of 2022 (the...more
3/16/2023
/ Affiliates ,
Anti-Inversion Regulations ,
Canada ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
IRS ,
New Guidance ,
Publicly-Traded Companies ,
Stock Repurchases ,
Subsidiaries ,
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 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
Current closures at the Internal Revenue Service (“IRS”) have caused significant delays in obtaining an Employer Identification Number (“EIN”) for some U.S. businesses formed by Canadians, including new U.S. subsidiaries...more