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North America

  • US tax developments

    US tax developments in the areas of repatriations, inversions and foreign tax credits will significantly affect planning for international transactions and foreign investments, explain Larissa Neumann and William Skinner of Fenwick & West.

  • New Canadian FA dumping and upstream shareholder loan rules

    In its March 2012 Budget, the Canadian federal government proposed a sweeping and aggressive set of new rules (the FA dumping rules) intended to curtail a practice known as foreign affiliate dumping. A subsequent iteration of the draft rules included a companion relieving rule to allow for upstream shareholder loans in certain circumstances, explain Paul Stepak and Sabrina Wong of Blake, Cassels & Graydon.

International Correspondents