The Resource Tax ramifications of nonresident purchases of Canadian businesses

Tax ramifications of nonresident purchases of Canadian businesses

Label
Tax ramifications of nonresident purchases of Canadian businesses
Title
Tax ramifications of nonresident purchases of Canadian businesses
Creator
Subject
Language
eng
Summary
This article reviews some of the issues surrounding purchases of Canadian businesses for U.S. investors and the impact of the Fifth protocol to the Canada-U.S. treaty on those purchases, including purchaser's objectives, financing considerations, thin capitalization, Canadian holding companies, unlimited liability companies, proposed changes in Nova Scotia, double-dip strategies, tax cost of Canadian assets, real estate, change of control, internediary holding company, exchangeable shares, repatriation of funds, interest payments to nonresident investors, management fees, loans, and disposition of shares
Citation source
In: Tax notes international. - Arlington. - Vol. 48 (2007),
http://library.link/vocab/creatorName
Bernstein, J
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • tax treaty
  • thin capitalization
  • holding company
  • unlimited liability company
  • double dipping
  • immovable property
Label
Tax ramifications of nonresident purchases of Canadian businesses
Instantiates
Publication
Label
Tax ramifications of nonresident purchases of Canadian businesses
Publication

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