Canada: Highlights From The Toronto Centre CRA & Tax Professionals Groups Breakfast Seminar (November 6, 2014)

On November 6, 2014 at the Toronto Centre Canada Revenue Agency & Tax Professionals Breakfast Seminar, representatives from the CRA provided an update on the Income Tax Rulings Directorate (“Rulings”) and discussed current topics of interest.
Income Tax Rulings Directorate Update
Mickey Sarazin, Director General of the CRA’s Income Tax Rulings Directorate in Ottawa, presented on recent developments at Rulings.

Mr. Sarazin noted that 10 years ago Rulings received approximately 500 ruling requests whereas today Rulings receives approximately […]

By |November 10th, 2014|

Luxembourg Leaks: Potential Risks To Companies Whose Luxembourg Tax Rulings Have Been Released To The Public

This week, the so-called “International Consortium of Investigative Journalists” (“ICIJ”), on its website, leaked a total of 548 tax rulings that multinational companies obtained in Luxembourg in the period from 2002 to 2010.

The list of companies whose rulings were disclosed includes some of the largest multinationals not only from the U.S. and Europe but also Japan, China, Russia, Brazil, and other countries. The ICIJ alleges that these companies “have channelled hundreds of billions of […]

By |November 10th, 2014|

United States: Service Legal Memorandum Issued On Foreign Tax Credits Paid By Foreign Subsidiary Are Ineligible For Crediting To U.S. Parent Corporation

In a recently issued and published (FOIA) IRS Legal Memorandum, ILM 201441015, the IRS concluded that a domestic parent corporation will not be deemed to have paid foreign income taxes under sections 902 and 960, which taxes in fact were paid by its foreign subsidiary as a result of a foreign tax redetermination. The facts also involved a complex corporate restructuring of various foreign subsidiaries several of which converted into defective entities in accordance […]

By |November 10th, 2014|