The Future of Cross-Border Financing After Final U.S. Anti-Hybrid Tax Rules

Date

April 23, 2020

Time

50 MIN

Delivery Method

Webinar (On Demand)


Overview

The final and proposed anti-hybrid regulations issued by the IRS on April 8, 2020 mark a key turning point in how cross-border financings across the Canada-U.S. border will be done. In order to evaluate this new legal landscape and the impact that these rules may have on the cost of capital for financing U.S. operations, Canadian companies should be carefully reviewing these rules, as well as their options going forward. Key topics will include:

  • the impact of the final 267A regulations on interest-free loan structures

  • effective date considerations

  • what changed and what didn't in the final 267A regulations

  • the future of cross-border financings 

The Future of Cross-Border Financing After Final U.S. Anti-Hybrid Tax Rules

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CLE/CPD Credit Information

Ontario – Substantive - 0.75

Quebec – General credits - 0.75

Speaking
Speaker

Jennifer Lee

Partner, Taxation

Speaker

Paul Seraganian

New York Managing Partner