Canada: Favourable Tax Measures Announced For Mining Investors

On March 1, 2015, the federal government announced two new tax measures favourable to investors in junior mining exploration companies in Canada in an effort to stabilize and strengthen the Canadian mining industry.

First, the government has extended the 15% Mineral Exploration Tax Credit for investors in flow-through shares for an additional year, until March 31, 2016. Flow-through shares are an instrument to encourage investment in Canadian mining, because they permit resource companies to renounce […]

By |March 5th, 2015|

UK: Good News For The Skiing Chalet And The Villa In The South Of France

For clients owning property in continental Europe, one big problem has always been what happens to the property on death, and the tax implications then. Most continental European countries including Italy, France and Spain impose ‘forced heirship’ rules, so that owners of real property situated in the country must leave a share of the property directly to their children on death and cannot leave all of it to their spouse. This often means the […]

By |March 4th, 2015|

United States: Nonrecourse Debt Affects Mark-To-Market Calculation

The IRS concluded in an internal legal memorandum (ILM 201507019) released Feb. 13 that a taxpayer’s nonrecourse liability affected its mark-to-market computation under Section 475(a).

Under the facts of the ILM, two commonly controlled partnerships were engaged in originating and purchasing mortgage loans and issuing notes to third-party investors as mortgage-backed securities (Notes) in exchange for cash. The partnerships treated the proceeds from the Notes as nontaxable loan proceeds, and the Notes were nonrecourse liabilities […]

By |March 4th, 2015|