2006 Articles

Barbados on US dividend list: Dec-28-2006 — The IRS recently announced that Barbados has been formally added to the list of foreign countries that qualify for the 15 percent preferential U.S. federal tax rate on dividends paid by a foreign corporation to U.S. non-corporate shareholders.
IRS targets employees of foreign embassies and international organizations: Dec-15-2006 — According to the IRS, a significant number of employees and former employees of foreign embassies, foreign consular offices, and international organizations in the United States fail to fulfill their U.S. income tax responsibilities.
Borders don't have to be barriers: Dec-04-2006 — Ten things you should know about how Hodgson Russ assists Canadian companies with their U.S. legal needs.
Multistate tax issues: Nov-30-2006 — For Canadian companies doing business in the United States, nexus is the most talked-about issue from a US state tax perspective. Many companies fail to realize that a treaty-based exemption generally won't provide protection from state taxes.
Overview of the US Transfer Tax System: Sep-01-2006
Temporary inversion regs: Aug-31-2006 — The new regs are Treasury's second round of guidance on the scope of the inversion rules and offer welcome clarification on what constitutes an "indirect" acquisition of substantially all of the assets of a domestic corporation or partnership.
Portfolio debt and partnerships: Jul-31-2006 — To help US companies raise capital, the United States provides tax incentives to encourage foreign investment in the US marketplace.
New FIRPTA guidance: Jun-30-2006 — New IRS regs revise rules for inbound and foreign-to-foreign asset reorganizations involving the transfer of US real property interests (USRPIs) pursuant to the Foreign Investment in Real Property Tax Act (FIRPTA).
PFIC lookthrough ruling: May-31-2006 — The IRS has interpreted favourably the lookthrough rule for 25 percent owned subsidiaries of foreign (non-US) corporations.
Reducing litigation risks in US business transactions: May-18-2006 — A failed deal is bad enough; having to contend with the expense and uncertainty of litigation can be a catastrophe. This is even more so for cross-border transactions, given the marked differences between the Canadian and U.S. legal systems.
Corporate inversions update: Apr-28-2006 — Three recent proposals clarify and modify the US corporate inversion tax rules enacted in 2004. The rules affect a wide range of cross-border transactions, including transfers of certain US-situs property to Canadian holdcos to avoid US estate tax.
Final US regs: Foreign mergers: Feb-28-2006 — The IRS has adopted final regs governing the type of transaction necessary to establish tax-free reorganizations under Code section 368. Tax-free statutory mergers or consolidations can now be effected under foreign law and can involve foreign entities.
Final and Temporary PFIC Regs: Feb-01-2006 — On December 8, 2005, the IRS issued final, temporary, and proposed regulations providing guidance for taxpayers that continue to be subject to the passive foreign investment company (PFIC) excess distribution regime of IRC § 1291.

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