Vitaly Timokhov speaks at the 19th Taxation of Corporate Reorganization Conference

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On January 20, 2015, Vitaly Timokhov, a tax lawyer and the firm’s partner, will speak at the 19th Taxation of Corporate Reorganization Conference (Federated Press) in Toronto, Canada.  Vitaly will speak on the Canada – U.S. Current Cross-Border Tax Update.

Vitaly’s presentation will examine developments in Canadian and U.S. cross-border tax rules as well as new proposals under review that will affect both inbound and outbound planning, and the implications for tax-efficient structuring and financing of an M&A and other reorganizations. The following topics will be covered in the course of the presentation:

  • Recent legislative and administrative changes and the impact on cross-border investment between Canada and the U.S.
  • FATCA’s application to M&A
  • U.S. limited liability companies and other fiscally transparent entities
  • Article IV(7) of the Canada-U.S. Treaty and its application to payments made by Canadian unlimited liability companies
  • Canadian GAAR: cross-border debt financing and restructuring
  • Article XXIXA (Limitation of Benefits) of the Canada-U.S. Treaty
  • Canadians investing in the U.S.: U.S. LLCs or partnerships?
  • REPOs and the Foreign Tax Credit Generator Rules

For more information and registration, visit the Federated Press:  http://www.federatedpress.com/19th-Taxation-of-Corporate-Reorganization.html 

TaxChambers LLP Tax Lawyers & Advisors is a tax law firm located in Toronto’s financial district. Our tax lawyers advise and represent clients from Canada and internationally in all areas of Canadian and U.S. tax law such as corporate and business taxation, international and cross-border taxation, transfer pricing, personal tax and wealth planning, sales and commodity taxes (GST/HST).