The Cross-Border Quarterly Report is a snapshot of transactional activity across the Canada-U.S. border. The purpose of this report is to provide a quick download of market trends, actionable insights for decision-makers and to keep our readers ahead of the curve on where the cross-border market is heading.
A primer for the new U.S. anti-hybrid rules
On December 20, 2018, the U.S. Department of the Treasury (the Treasury Department) released eagerly anticipated proposed regulations designed to combat the use of cross-border hybrid financing arrangements. These regulations, issued under new Section 267A of the U.S. Internal Revenue Code, are aimed at preventing the use of arrangements involving hybrid transactions or hybrid entities to affirmatively exploit differences in the tax laws across jurisdictions. This regulatory proposal represents a game-changing escalation of the U.S. tax system's commitment to neutralize the use of hybrid arrangements that erode the U.S. tax base.
What you need to know about these new rules and their application
CPTPP implemented in Canada: Opportunities and challenges for Canadian businesses
On December 30, 2018, the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) was implemented as between Canada, Australia, Mexico, New Zealand, Japan and Singapore. Once fully implemented, the CPTPP will create a trading bloc made up of almost half a billion consumers and representing 13.5% of the global GDP. We outline some of the key provisions of the CPTPP and why this presents some immense opportunities as well as challenges for Canadian businesses.
Why Canadian businesses should review their strategies
Legal Year in Review: From cannabis to U.S. tax reform
The cross-border business landscape in 2018 saw a number of major legal developments that are reshaping the way Canadians conduct and execute their cross-border business strategies. From Canada becoming the first G7 country to legalize retail cannabis — and Canadian cannabis companies conquering U.S. capital markets — to U.S. tax reform and more, we offer insights on the key things Canadians should be cognizant of.
Read more in our 2018 Legal Year in Review
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
