fmc-law.com RSS Feeds - Publications - Cross-Borderhttp://www.fmc-law.com/upload_net/rss/en/Cross_Border.xmlThu, 31 May 2012 10:01:11 GMTen-us5Among the more significant proposed changes to the Income Tax Act (Canada) (the “Act”) announced in the March 29, 2012 federal Budget (the “Budget”) are the so-called “foreign affiliate dumping” rules that will affect Canadian resident corporations controlled by non-resident shareholders where the Canadian corporation invests in foreign affiliates. A number of technical issues arise under the proposed legislation. This article briefly reviews the proposed legislation, and specifically considers the application of the new rules where the Canadian-resident corporation is an unlimited liability company (“ULC”).http://www.fmc-law.com/Publications/0512_What_Happens_If_Your_CRIC_Is_A_ULC.aspxThu, 17 May 2012 06:00:00 GMThttp://www.fmc-law.com/Publications/0512_What_Happens_If_Your_CRIC_Is_A_ULC.aspxThe March 29, 2012 Canadian federal budget (the “Budget”) proposes a number of changes to Canada’s thin capitalization rules that may have significant implications to cross-border financing. Clients should review existing financing arrangements to assess the potential implication of these changes and must carefully consider proposed Canadian investments to ensure compliance with the new regime. Read more by clicking the download button.http://www.fmc-law.com/Publications/0512_Beefing_Up_Canada_Thin_Capitalization_Rules.aspxSun, 01 Apr 2012 06:00:00 GMThttp://www.fmc-law.com/Publications/0512_Beefing_Up_Canada_Thin_Capitalization_Rules.aspxThe Canada Border Services Agency (CBSA) has recently released its 23 “target” national audit priorities for the coming year.  In addition to the national audit priorities listed below, the CBSA is also conducting audits of large file importers and other strategic targets.  Importers who do not plan for a potential customs audit do so at their own peril. The following information will highlight some of the current CBSA audit priorities and give some insight into how to prepare for a CBSA audit and manage potential risk from customs duty, punitive interest and penalty assessments that could arise in the event of a negative CBSA audit finding.  Proper planning and the implementation of appropriate compliance measures will assist importers in avoiding these potential customs risks. Read more by clicking the download button.http://www.fmc-law.com/Publications/0611_Focus_On_Tax.aspxTue, 28 Jun 2011 06:00:00 GMThttp://www.fmc-law.com/Publications/0611_Focus_On_Tax.aspx