Canadian Tax Fundamentals: Withholding Tax On Cross-Border Interest Payments

Canadian withholding tax must always be considered in any cross-border financing. A failure to fully appreciate and mitigate the potential withholding tax risks can have significant adverse tax and cash flow implications to the parties, including personal liability for the directors of a corporate borrower.

Withholding tax will not always apply to cross-border interest payments, but the precise circumstances in which it either will or will not can be ambiguous. In many instances the analysis […]

By |September 30th, 2014|

United States: New Study By UAB Professor Analyzes Collateral Damage From Internet Sales Tax Non-Compliance

In 2012, Dr. Robert A. Robicheaux, well-respected Professor in the Department of Marketing, Industrial Distribution and Economics at the University of Alabama at Birmingham’s Collat School of Business, issued a report titled “Estimates of Alabama Losses Due to E-Commerce.” The detailed report analyzed Alabama’s economic losses from purchases by its businesses and consumers from out-of-state vendors who did not remit state and local sales or use taxes. In this new report, “Tax Collections on […]

By |September 29th, 2014|

United States: Photographers Owe Sales Tax On All Charges Other Than Retainer

On September 8, the Alabama Department of Revenue’s Administrative Law Division (the “ALD”) issued a ruling that will likely send shock waves to photographers across the state, and if not successfully appealed or if applied retroactively, could cause a financial hardship and a significant change in the way they do business. In Jaclyn L. Robinson d/b/a Robinson Studio & Design v. State Dep’t of Rev., Admin. Law Div., Dkt. No. S. 13-807 (Sep. 8, 2014), […]

By |September 29th, 2014|