Cross-border debt financing is a central and battle-tested element of international tax planning for Canadian companies with U.S. operations and investments. New proposed taxation regulations by the U.S. Treasury Department and IRS have the potential to profoundly disrupt the manner in which cross-border debt instruments are planned for, implemented and managed. The broad scope of these rules and the serious tax consequences they entail are significant for any Canadian company with U.S. activities.
Please join members of Osler’s cross-border tax practice for a practical discussion of these rules. Topics include:
- A practical overview of the regulations, including;
- documentation requirements;
- bifurcation of an instrument into part-debt and part-equity;
- distribution and acquisition transactions that could cause mandatory equity characterization of related-party debt;
- The impact of the regulations on common Canada/U.S. financing structures; and
- Positioning your companies or investments in anticipation of the final regulations
This discussion is designed to address issues that will be relevant across all industries as well as private equity funds and pension funds with portfolio investments in U.S. companies.
Speakers - Osler's Cross-border Tax Lawyers
Sue Wooles, Director, Taxation, BMO Financial Group
To attend this session in-person, please contact Lindsay Taylor email@example.com to register.
For webinar registration, click here.