In this article from Tax Notes International, Davies partner Nathan Boidman provides updates about the Canada Revenue Agency’s May 26, 2016, non-binding administrative decision to treat certain U.S. limited liability partnerships (LLPs) and limited liability limited partnerships (LLLPs) as corporations and reports on an announcement this past April to substantially liberalize the transitional rules for pre-existing LLPs/LLLPs.
U.S. Supreme Court Upends 40 Years of Judicial Deference to Regulations
July 25, 2024 - In a historical opinion in Loper Bright Enterprises v. Raimondo, Secretary of Commerce, released at the end of June, the U.S. Supreme Court overturned the “Chevron” doctrine, which for so long had controlled judicial review of U.S. federal regulations. Chevron, decided in...
Canada Finally Enacts the Digital Services Tax (Maybe)
July 09, 2024 - The new Digital Services Tax Act came into force with an order-in-council on June 28, 2024, imposing a 3% digital services tax (DST) on certain Canadian-source digital services revenue of large entities. The DST would first be payable in 2025, with the initial payments retroactively...
