Canada: Sell Now! (How the 2014 Budget May Impact on Business Owners’ Exit Strategies)

The federal government’s 2014 Budget contained a host of changes, including “proposals” to change the taxation of eligible capital property (i.e., goodwill, patents, trademarks, intellectual property, etc.) so that it will be taxed in the same way that gains on other depreciable capital property (e.g. equipment, commercial vehicles, etc.) are taxed. While changes to the eligible capital property (“ECP”) regime seem logical and innocuous at first glance, if implemented these changes will lead to […]

By |November 13th, 2014|

UK: Collateral Debt

With effect from 4 August 2014, HMRC changed, without notice, their stated position with respect to the treatment of commercial loans secured by foreign income or gains. From this point on, money brought to or used in the UK under a loan facility secured by foreign income or gains is to be treated as a taxable remittance in addition to any service payments. Prior to this, HMRC guidance was that only repayments or payments […]

By |November 13th, 2014|

United States: New IRS Rules On Direct Rollovers Of Taxable And Non-Taxable Amounts Require Changes To Defined Contribution Plan Administration By January 1, 2015

The Internal Revenue Service (IRS) recently released guidance allowing participants to allocate the taxable and non-taxable portions of a single distribution from a defined contribution retirement plan into separate accounts.  The rules apply to distributions beginning January 1, 2015, though participants may select an earlier applicability date in certain circumstances.  Sponsors of defined contribution retirement plans should consider how their administrative practices and participant communications may need to be changed in light of these […]

By |November 13th, 2014|