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North America

  • Taxation developments in North America

  • Surprising changes to Canada's foreign affiliate rules

    On August 19 2011 the Canadian Department of Finance released a package of proposed amendments to Canada’s Income Tax Act (ITA) that contained several surprising changes to Canada’s foreign affiliate rules. Sabrina Wong and Kirsten Kjellander of Blake, Cassels & Graydon discuss the changes and what they will mean for Canadian taxpayers.

  • How to navigate economic substance guidance

    On July 15 the Internal Revenue Service’s (IRS) Large Business & International (LB&I) division issued guidance to IRS examiners and examination case managers in the form of a directive concerning the application of the economic substance doctrine (ESD) that was recently codified in section 7701(o) of the Internal Revenue Code. Andrew Kim and William Skinner of Fenwick & West explain how taxpayers can navigate through the ESD, and also discuss recent US tax developments.

International Correspondents