United States | Publication | April 2022
The throwback tax is the US tax law’s main tool for discouraging tax-free accumulation of income by foreign non-grantor trusts for US beneficiaries. Its complex rules are a dangerous minefield that should be avoided. This article reviews the operation of the throwback tax rules, and assesses the effectiveness of this trust anti-deferral regime in various fact patterns. It also discusses how the trust anti-deferral regime interacts with the US law’s foreign corporation anti-deferral regime, another minefield.
Publication
On October 22, 2024, the Canada Industrial Relations Board (CIRB) published written reasons for a decision delivered verbally on August 24, 2024.
Publication
Following the commencement at 12:01 a.m. on Friday, November 15, of a national strike by the Canadian Union of Postal Workers, shutting down Canada Post’s operations across the country, the Canadian Securities Administrators (CSA) have published guidance recommending that all stakeholders required to deliver documents to securityholders contact their local securities regulator or visit their local regulator’s website for guidance.
Publication
The Canadian Intellectual Property Office (CIPO) is undergoing a modernization effort to provide a new online portal for patent services that serves as a centralized online platform for filing, tracking and managing patent files.
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