Matias Milet Matias Milet

Canadian anti-hybrid tax legislation released in draft

On April 29, 2022, the Department of Finance released the first of two packages of draft legislation to implement its proposals to eliminate the tax...

136 countries agree to OECD/G20 Inclusive Framework’s two-pillar solution to international tax reform

Last week, 136 countries, including Canada and the United States, announced that they have agreed to the OECD/G20 Inclusive Framework’s two-pillar...

A discordant jurisprudence: what does it mean to be ‘Acting in Concert’?

Under the Income Tax Act (Canada) taxpayers are deemed to not deal at arm’s length if they are “related”. In all other circumstances, taxpayers...

Exchangeable share structures – an overview

Exchangeable share structures have been a fixture in structuring cross-border share exchange mergers and acquisitions involving Canadian corporations...

Continued uncertainty following recent CRA position on Tax Treaty anti-avoidance rule

The most significant treaty modification implemented through the MLI was the addition of a broad anti-avoidance rule known as the principal purpose...

Managing Canadian investment entities in the U.S.

Investment entities in the United States that happen to reside in Canada now have detailed guidance for determining their status under the Foreign...

Managing non-Canadian private equity funds in Canada

Non-Canadian private equity fund sponsors can be subject to a number of Canadian tax issues when engaging Canadian service providers, raising capital...