What Canadian Companies and Their Advisers
Need to Know about U.S. Law
Many Canadian companies and individuals own U.S. real property interests through a U.S. corporation. The Foreign Investment in Real Property Tax Act (“FIRPTA”) regime imposes a withholding tax (currently at a rate as high as 15%) on the gross proceeds realized by Canadians upon the sale or transfer of a U.S. real property interest. This...
Canadian companies should carefully structure and document loans and advances to their U.S. subsidiaries. If loans to U.S. subsidiaries are not properly structured and documented, such loans may be recharacterized as equity investments for U.S. federal income tax purposes, and important U.S. tax benefits will be lost. Properly structured loans are treated as debt for...
Cross-Border Counselor is a collection of articles and timely updates about U.S. law issues of concern to Canadian companies that have assets, do business, raise funds or are listed for trading in the United States, as well as the attorneys, accountants and banks that advise them. Learn more about Dorsey’s Canada cross-border practice group here.
Christopher L. DoerksenChris helps clients raise money by selling equity and debt, buy and ...
James GuttmanJames advises publicly-traded companies and closely-held companies ...
Randal R. JonesRandy has over 25 years of experience counseling emerging, priv...
Aaron GoldsteinAaron is a Partner in Dorsey’s Labor & Employment group, where he brin...
Kendall R. FisherKendall’s practice focuses on U.S. federal tax issues related to dome...
Marina LyonsMarina is a Partner in Dorsey’s Labor & Employment group. Ha...
Jenna SteinerJenna assists employers in drafting, implementing, and administe...
Larry WardAs an international business attorney, Larry helps clients navigate com...
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