Originally published in Tax Notes International, this article examines new obstacles to the recovery by foreign parties of funds that were invested to indirectly acquire, through foreign companies, Canadian targets, raised by the recent decision in Univar and related proposed amendments to certain surplus stripping rules.
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...
