Short-term and taxable preferred shares: Think before you dividend
Introduction Dividend sits among the group of the most pleasant words in the English language. The crescendo of the single letter syllable in the middle of the word creates a satisfying enunciation when spoken. The connotation of the receipt of […]
Consultations on measures announced in Budget 2023 begin
On Friday, August 4, 2023, the Department of Finance released for public consultation extensive legislative proposals accompanied by explanatory notes (the “August Proposals”). The August Proposals relate to various measures previously announced in Budget 2023. See here for our 2023 […]
Selling your partnership interest? The possible impact of subsections 100(1) and (2) of the Income Tax Act
When a partnership interest is sold by a taxpayer, the taxpayer may realize a capital gain to the extent the taxpayer’s proceeds of disposition for the partnership interest exceed the total of the adjusted cost base (the “ACB”) of the […]
New considerations when seeking to multiply access to the lifetime capital gains exemption
Proactive planning to multiply access to the lifetime capital gains exemption (“LCGE”) for shares of a qualified small business corporation (“QSBC”) or qualified family farm property (“QFFP”) remains of ongoing interest to taxpayers and their family members that may be […]
New reportable transaction rules receive Royal Assent
Bill C-47 received Royal Assent on June 22, 2023, bringing into effect the new expanded reportable transaction rules. A failure to report as required by the new rules could result in substantial penalties for both taxpayers and their advisors. Taxpayers […]
Zero-rated supplies: Do not forget the burden of proof!
The burden of proof in tax matters is a topic frequently addressed by commentators and dealt with in provincial and federal case law. However, the concept itself is sometimes confused with other tax concepts. For example, many taxpayers consider the […]
Intergenerational business transfers: Bill C-208 developments
Prior to 2021, section 84.1 of the Income Tax Act (“Act”) created a real impediment to a tax-efficient succession of a family business from one generation to the next, effectively penalizing a sale to a family member compared to an […]
Employee ownership trusts in Canada: Plan carefully to avoid unintended tax consequences
In the United States and the United Kingdom, an employee ownership trust (“EOT”) is a common option for business owners seeking to transfer their business to employees or to establish an employee remuneration plan. In Canada, several different provisions of […]
Underused housing tax – Canada Revenue Agency publishes additional guidance
The underused housing tax (the “UHT”) is a new 1% federal tax aimed at taxing vacant or underused housing owned by non?Canadians. Specifically, the UHT affects “owners” (except “excluded owners”) of “residential property” located in Canada. While many Canadian and […]
Fairness and economic substance: Select comments on the proposed changes to the General Anti-Avoidance Rule
Canada’s 2023 federal budget was released on March 28, 2023 and contained proposals for changes to the general anti-avoidance rule (“GAAR”). We published a summary overview of the proposed changes to the GAAR on March 28. This article provides some […]
Federal Court of Appeal affirms application of Subsection 84(2) of the Income Tax Act (Canada) to a hybrid business sale transaction
In the context of a sale of a business operated by a corporation, the seller and buyer typically have competing interests. Whereas sellers tend to prefer selling their shares of the corporation so that they can receive the sale proceeds […]
Hydrogen: Hollywood fiction, tax facts, and what’s in it for producers
Hollywood loves science fiction and the future. So-called “genre” films, featuring futuristic scenarios, humans with fantastic supernatural abilities, and new technologies dominate the cinemas and streaming market. Many commentators have speculated that the enduring fascination with such productions lies in […]
Before setting off on the yellow brick road of tax controversy, do you know where it leads?
Dealing with tax authorities can be very distressing for taxpayers. Correspondence from the tax authorities often contain deadlines which are easy for the taxpayer to miss. In a recent Tax Court of Canada decision, Osadchuck v. The King, 2023 TCC […]
Canadian individuals and corporations may have an underused housing tax filing obligation even when no tax is owed
Editor note: On March 27, 2023, the Canada Revenue Agency announced that “no penalties or interest will be applied for UHT returns and payments that the CRA receives before November 1, 2023”. This announcement effectively extends the filing and payment […]
2023 Canada Federal Budget: A Summary
Canada’s Minister of Finance (and Deputy Prime Minister) tabled Canada’s federal budget for 2023 (“Budget 2023”) on March 28, 2023 (“Budget Day”). While there is good news insofar as Budget 2023 does not propose any increases in tax rates or […]
The new Underused Housing Tax: Are you tax exempt?
The Underused Housing Tax (the “UHT”) is a new annual 1% tax payable by an “owner” (other than an “excluded owner”) of “residential property”. A “residential property” includes, among other things, a detached house, a duplex, a triplex, a row-house […]
Minimizing tax losses: The Solana hack
Throughout the year, many blockchains have been attacked by hackers. These loss events are indicators of the significant losses the cryptocurrency market has experienced. For investors who have suffered, an important consideration is how to utilize these losses. Accordingly, this […]
The reasonableness of reasonable
The word “reasonable” has been part of Canadian tax lexicon for over a century. The 1917 Income War Tax Act allowed at para. 3(1)(a) a deduction in the computation of income for “such reasonable allowance as may be allowed by […]
( Available in French only )
Vous vendez votre participation dans une société de personnes? Les conséquences potentielles des paragraphes 100(1) et (2) de la Loi de l’impôt sur le revenu
Le présent numéro du Bulletin fiscal aborde certains aspects fiscaux à prendre en considération lors de la vente d’une participation dans une société de personnes. La vente d’une participation dans une société de personnes peut donner lieu à des gains […]
Trust planning and the notifiable transaction rules: Where do we go from here?
In 2022, the Department of Finance released draft legislation that includes, as part of a new regime of mandatory reporting rules, the notifiable transaction rules (“Rules”). The Rules are set to apply in a wide range of tax planning areas, […]
Minimizing tax losses: The TerraUSD and LUNA collapse
Throughout the year, many cryptocurrencies have collapsed. These loss events are indicators of the significant losses the cryptocurrency market has experienced this year. For investors who have suffered losses, an important consideration is how to capitalize on these losses. Accordingly, […]
Toronto and Ottawa vacant homes tax: Don’t forget to file your declaration for 2022!
In 2022, Toronto and Ottawa introduced vacant homes tax regimes.[1] These regimes are modelled after the empty homes tax regime introduced in Vancouver in 2017, and are aimed at incentivizing owners of vacant residential properties to sell or rent their […]
The Celsius bankruptcy and application of the bad debt rules
Many cryptocurrency lenders have declared bankruptcy. These loss events are indicators of the significant losses the cryptocurrency market has experienced this year. For investors who have suffered, an important consideration is how to capitalize on these losses. Accordingly, this article […]
“Checking the Box” not enough to avoid director’s liability for outside director
A decision of the Tax Court of Canada has provided further insight into the duties of an “outside” director who wishes to rely on the due diligence defence to avoid a director’s liability assessment under the Income Tax Act (the […]
Federal Government targeting independent contractor arrangements with road transportation workers
Businesses in the trucking industry may soon face increased scrutiny from the Federal Government respecting the classification of drivers as independent contractors. With the release of the 2022 Fall Economic Statement, it was announced that the Federal Government will allocate […]
Tax treatment of stock options granted to independent contractors
The tax treatment of stock options granted to employees has been well established by the Income Tax Act (Canada) (the “ITA“) and related commentary. In particular, Section 7 of the ITA contains the taxation rules for stock options granted to […]
Implementation of enhanced trust reporting requirements delayed one year
We previously wrote on Finance Canada’s proposed expansion of the reporting requirements for Canadian trusts, including the proposed expansion of the rules to capture bare trust arrangements. You can read our latest article here. The new filing and reporting requirements […]
Is the burden of proof in tax litigation always on the taxpayer?
Burden of proof is a complex subject in Canadian tax litigation and has been heavily debated in recent years. While many mistakenly think the concept can be summarized by the often-heard phrase “the burden of proof in tax matters is […]
( Available in French only )
Dans les litiges à caractère fiscal, le fardeau de la preuve incombe-t-il toujours au contribuable?
Au Canada, dans les litiges à caractère fiscal, le fardeau de la preuve est un sujet complexe qui a fait l’objet de vifs débats ces dernières années. Bon nombre de personnes pensent à tort que ce concept se résume par […]
The increasing popularity earnouts
Due to the economic impact of the COVID-19 pandemic and the recent volatility of stock markets, we have noticed an increased perceived valuation gap between vendors and purchasers in the context of M&A transactions. As a result, contingent consideration arrangements […]
A primer on ABIL claims: Part II
Primer on when you can claim ABIL This article will be the second in a series of articles that discusses the Allowable Business Investment Loss (“ABIL”) within the meaning of the Income Tax Act (Canada) (“Act”). In particular, this article […]
A primer on ABIL claims: Part I
What is an ABIL? This article will be the first in a series of articles that discuss the Allowable Business Investment Loss (“ABIL”), including the interpretation of key terms as well as a discussion of recent case law. Where a […]
Is your partnership allocation method reasonable? The ability of tax authorities to reallocate income and losses of a partnership
Partnerships are frequently used in various legal structures as they can be a beneficial vehicle to address certain business needs. Despite the advantages of using a partnership, partners must nevertheless take into account the potential taxation issues that may arise. […]
Books and records: Document retention policies and best practices when dealing with the CRA
The proper maintenance of a business’ books and records is essential when dealing with an audit initiated by the Canada Revenue Agency (the “CRA”). Taxpayers should be cognisant of their recordkeeping obligations under the Income Tax Act (Canada) (the “Act”) […]
Proposed amendments to the foreign affiliate rules
Introduction On August 9, 2022, the Department of Finance (“Finance”) released details of proposed changes to the Income Tax Act (the “ITA”). A number of the proposed changes impact the rules relating to “foreign affiliates” as defined by the ITA. The most […]
Changes to the substantive CCPC rules
On August 9, 2022, legislative proposals relating to the Income Tax Act (the “Act”) and other tax legislation were released by the Department of Finance for public feedback (the “August Proposals”). The August Proposals seek to implement certain measures previously […]
Release of draft Canadian tax legislation
On August 9, 2022, legislative proposals relating to the Income Tax Act (the “Act”) and other tax legislation were released by the Department of Finance for public feedback (the “August Proposals”). The August Proposals seek to implement certain measures previously […]
Is the interest deductible? – Fundamentals of interest deductibility in Canada
The rules around interest deductibility are becoming more and more complex. As a business grows and expands their operations to new jurisdictions, and adopts a corporate structure designed to take advantage of certain opportunities related to interest deductibility, the business […]
Failed claim of solicitor-client privilege: Commentary on Minister of National Revenue v. BMO Nesbitt Burns Inc., 2022 FC 157
In the 2022 case, Minister of National Revenue v. BMO Nesbitt Burns Inc., the Minister of National Revenue (the “Minister”) made an application pursuant to section 231.7 of the Income Tax Act (Canada) (the “Act”) for an order requiring BMO […]
Cryptocurrency and tax reporting obligations
Background framework Section 233.3 of the Income Tax Act (Canada)[1] (the “ITA”) requires Canadian resident taxpayers (subject to certain exceptions) and partnerships with Canadian resident members (subject to certain exceptions) (each referred to as a “specified Canadian entity”) to report […]
What should I do with my non-CCPC?!?!
Taxpayers who previously engaged in non-CCPC tax planning have a decision to make – and ideally soon. For context, in recent years, a number of Canadian taxpayers implemented planning that involved causing a Canadian-controlled private corporation (“CCPC”) to cease to […]
Why online marketplaces and e-commerce businesses should review their Canadian sales tax obligations
Online marketplace platform operators and facilitators, and other e‑commerce businesses, that did not have Canadian sales tax obligations when they first started operations may now find that they are required to register for, and collect, Canadian sales tax in one […]
New PST for admission and entertainment charges in Saskatchewan: Businesses need to be prepared
Going to see your favourite band play or sports team compete is about to cost more in Saskatchewan. With the release of the 2022-2023 Saskatchewan Provincial Budget, it was announced that the Province’s provincial sales tax (“PST”) would be expanded […]
Recent changes to pertinent loan or indebtedness (PLOI) elections
On March 25, 2022, the Canada Revenue Agency (the “CRA“) issued a notice to tax professionals outlining certain changes to “pertinent loan or indebtedness” (“PLOI“) elections, including PLOI elections made in respect of cross-border shareholder loans under subsection 15(2.11) of […]
Post-COVID emigration: Don’t forget the tax!
As COVID-19 travel restrictions are lifted, individuals who are usually resident in another country but sheltered in place in Canada during the pandemic may decide to return to their countries of residence. Those individuals who are planning to leave Canada […]
Budget 2022: Substantive CCPCs and share transactions involving a non resident or public company
The 2022 Federal Budget was tabled in the House of Commons on April 7, 2022 (“Budget Day“) by the Honourable Chrystia Freeland, Canada’s Deputy Prime Minister and Minister of Finance. A summary of the personal income tax measures, business income […]
2022 Federal Budget Review
Introduction The 2022 Federal Budget was tabled in the House of Commons on April 7, 2022 by the Honourable Chrystia Freeland, Canada’s Deputy Prime Minister and Minister of Finance. With a Foreword that began with a thank you to Canadians […]
Luxury tax draft legislation (finally) released: May apply to certain vehicles, aircraft, and boats
On March 11, 2022, the draft legislative proposals relating to the Select Luxury Items Tax Act (the “Act”) were released for public comment. This new luxury tax was first announced in the 2021 Federal Budget, with a detailed backgrounder released […]
Release of draft Canadian tax legislation for public consultation
An extensive package of draft legislative proposals was released for public comment by the Department of Finance on February 4, 2022 (the “Proposals”) along with explanatory notes (the “Notes”). The Proposals include some, but not all, of the measures announced […]
The Underused Housing Tax Act: A primer
On December 15, 2021 the House of Commons held the first reading of Bill C-8, which includes draft legislation for a new stand-alone tax act: the Underused Housing Tax Act (the “Act”). Very broadly, the draft legislation intends to impose […]
Proposed limits on employee stock option deductions
Introduction The long-standing tradition of using employee stock options to reward and retain employees in Canada is expected to change for some employees due to limits proposed by the federal government to the current advantageous tax treatment available to employees […]
E-Commerce Businesses – Do you need to be registered for GST/HST?
Effective July 1, 2021, major changes to the GST/HST regime as it relates to e-commerce and the digital economy came into effect. We previously reported on these measures when they were first announced in the Fall Economic Statement 2020 and […]
Budget 2021 – Tax enforcement, audits, and oral interviews
Recently, Chrystia Freeland, Deputy Prime Minister and Minister of Finance, presented the 2021 Budget on behalf of the Government of Canada (“GOC”). Debits and Credits. The cornerstone of any accounting textbook. For the federal government, the debits (spending) have not […]
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Le privilège des communications entre client et avocat : d’une importance tout simplement cruciale!
Décisions de la Cour suprême du Canada Le vendredi 3 juin 2016, la Cour suprême du Canada (la « CSC ») a publié deux décisions importantes [Canada (Procureur général) c. Chambre des notaires du Québec et Barreau du Québec, 2016 CSC 20 (« Chambre des notaires »); et […]
Budget update – Sales, excise, and digital services tax
On April 19, 2021, the federal budget was tabled by Deputy Prime Minister and Finance Minister Chrystia Freeland (“Budget 2021”). Budget 2021 confirmed the measures first announced on November 30, 2020 in Supporting Canadians and Fighting COVID-19: Fall Economic Statement […]
What a non-resident vendor of goods needs to know about Canadian sales tax
When the federal goods and services tax (“GST”) was introduced in 1991, “Seinfeld” was on the air and most consumer goods were purchased at brick and mortar stores. Fast forward to 2021 and puffy shirts can be purchased online from […]
Expansion to BC PST registration and collection rules effective April 1, 2021
In Provincial Budget 2020, measures were announced that would require businesses not otherwise carrying on business in British Columbia (“BC”) to register for and collect PST. Amendments to the Provincial Sales Tax Act (British Columbia) (“BC PSTA”) were supposed to […]
COVID-19 relief for resource companies: Resource issuers may rely on proposed extensions
Resource companies that have issued flow-through shares shortly before or during the global COVID-19 pandemic may have faced difficulties, including the shutdown of mines, incurring eligible resource expenses within the normal timelines required under the Income Tax Act (Canada) (the […]
COVID-19: GST/HST remittance deferral measures
On March 27, 2020, Canada’s Department of Finance announced GST/HST remittance relief. Any payments or remittances, including installment payments, that become owing on or after March 27, 2020 and before June 30, 2020 can be deferred until June 30, 2020. […]
Retroactive changes to Saskatchewan PST applies to out-of-province online businesses
Saskatchewan imposes a 6% provincial sales tax (PST) on the retail sale or lease of most tangible personal property and taxable services (which includes software) consumed or used in the province. Where a sale of goods occurs in a brick-and-mortar […]
Canada Emergency Wage Subsidy: Revised rules for qualifying periods August through December
Bill C-20, An Act respecting further COVID-19 measures (“Bill C-20”), received Royal Assent on July 27, 2020. Bill C-20 enacts amendments to provisions of the Income Tax Act (Canada) that implement the Canada Emergency Wage Subsidy (“CEWS”). These amendments include […]
Is the Alberta advantage back?
The COVID-19 pandemic is having a devastating global economic impact. To boost the Alberta economy and attract more business, the Alberta Government has recently announced several measures. A. Repealing Residency Requirement for Directors U.S. and other foreign‑based businesses looking to […]
Miller Thomson represents CanLII in successful sales tax appeal
On July 17, 2020, the Tax Court of Canada found in favour of the Canadian Legal Information Institute (“CanLII”) (2020 TCC 56) on the basis that CanLII made a taxable supply with respect to the provision of a virtual library […]
Using anticipated losses within ownership structures
As much of Canada begins to loosen social restrictions surrounding Covid-19, many owners will be taking stock of the economic impact of the pandemic on their businesses. While the full economic picture is not yet known, many business are expected […]
Prescribed rate loans: Tax planning opportunity during uncertain times
The Canada Revenue Agency (the “CRA”) announced the prescribed rate for the third quarter of 2020 (“Q3”) on June 22, 2020. Starting July 1, 2020, the prescribed rate is 1% (reduced from 2% in the second quarter). The prescribed rate […]
Business Income Tax Measures
Small Business Tax Rate Currently, as a result of the small business deduction, the first $500,000 per year of qualifying active business income of a Canadian-controlled private corporation (“CCPC”) is subject to a federal income tax rate of 11%. Consistent […]
Canada Revenue Agency Eliminates Tax Deferral for Joint Ventures
CRA has announced that it is withdrawing its administrative position allowing participants in a joint venture (“JV”) to establish a fiscal period for the JV that differs from the fiscal periods of the JV participants. This change was made inevitable […]
Upstream Loans and Other Indebtedness to Foreign Affiliates
Draft legislation making significant changes to the foreign affiliate provisions of the Income Tax Act (Canada) (the “Act”) was released by the Department of Finance on August 19, 2011. The new provisions deal with upstream loans from and other indebtedness […]
COVID-19 pandemic economic measures for businesses
The federal government recently announced a new set of economic measures to help stabilize the economy during the COVID-19 pandemic. Outlined below are measures implemented by the federal government, along with expanded existing programs, that are designed to assist small, […]
The Canada Emergency Wage Subsidy: A welcome assistance for employers – a pitfall for the unprepared
Introduction Canadians have been blindsided by the COVID-19 health and economic crisis. The impact has been swift, painful, and enduring. In March 2020 alone, Canada lost a record one million jobs. In the face of this crisis, Parliament passed legislation […]
COVID-19 pandemic economic measures for individuals
The federal government recently announced a new set of economic measures to help stabilize the economy during the COVID-19 pandemic. Outlined below are new measures implemented by the federal government, along with expanded existing programs, that are designed to assist […]
COVID-19: Sales tax and tax controversy updates and insights
Businesses of all sizes are scrambling to adapt to the constantly changing world in which we find ourselves. Owners are worried about cash flow. Routine business operations are migrating online. New revenue streams are being explored. Meanwhile, we are inundated […]
To delay or not? Extensions by the CRA and the Tax Court of Canada
CRA has published its position on collections, audit, objections and appeals in light of the COVID-19 pandemic. Most noteworthy, CRA’s stated positions are the following: “Collections activities on new debts will be suspended until further notice, and flexible payment arrangements […]
Temporary layoff of employees: Tax obligations arising from contributions to a supplementary unemployment benefit plan
Employers that are contemplating or have established a supplementary unemployment benefit plan to assist their employees who are collecting benefits further to a temporary or indefinite layoff due to COVID-19 will have to keep in mind the tax consequences of […]
Rent deferral during pandemic may not reduce GST/HST payable on rent
The COVID-19 pandemic has created unique dilemmas or opportunities for all aspects of society. While select businesses are proving to be uniquely successful during the economic downturn, most businesses are in need of assistance in order to continue to exist. […]
Agreement with creditors: Beware
The unprecedented COVID-19 pandemic is having a significant financial impact on many Canadian businesses regardless of their size. A business experiencing financial difficulties may attempt to negotiate a full or partial reduction in amounts owed to its creditors. In such […]
Rebates on invoices: how to deal with GST and QST?
The current economic circumstances straining the liquidity of Canadian businesses will no doubt result in suppliers being required to grant rebates to recipients. This leads to the question as to whether suppliers are required to issue a credit note to […]
A Cautionary Tale Regarding the GST/HST New Housing Rebate
As an incentive to a prospective buyer, a builder may offer to provide a credit to decrease the purchase price of a newly-constructed or substantially renovated detached house, duplex, or condominium unit (collectively referred to as a “Home“) in exchange […]
Change to Canada-US Tax Treaty Affecting Cross-Border Employees
Article XV(2) of the Canada-US Tax Treaty (the “Tax Treaty”) provides for an exemption from taxation of remuneration derived by an employee resident in a country (referred to herein as “residence state”) in respect of temporary employment exercised in the […]
Cross-Border and International Tax: New Canadian Compliance Requirements for Non-Residents of Canada
Non-residents of Canada that are eligible for benefits under a tax treaty entered into between Canada and another country will now have to complete a declaration or provide equivalent information to avail themselves of any reduced rate of tax or […]
Cross-Border Tax: Canada-US Tax Treaty Update: CRA Views on Treaty Benefits on Dividends Paid by Canadian ULC’s
Treaty benefits will generally be denied under the new anti-hybrid rule under Article IV(7)(b) of the Canada-US Tax Treaty (the “Treaty”) in respect of any dividends paid on or after January 1, 2010 by Canadian unlimited liability corporations (“Canadian ULCs”). […]
Overview of Limitation on Benefits Article in Canada-U.S. Tax Treaty
The Canada-United States Tax Treaty (the “Tax Treaty”) is unique among Canada’s tax treaties in its approach to prevent “treaty shopping”. Treaty shopping generally refers to the acquisition and enjoyment of treaty benefits under a given tax treaty by persons […]
Canadian Tax Treatment of Mortgage Investment Corporations and Their Shareholders
A mortgage investment corporation (“MIC”) and its shareholders are entitled to special tax treatment under section 130.1 of the Income Tax Act (Canada) (the “Act”). These special rules were introduced to attract more money to the Canadian mortgage market for […]
Overview of New Canada-Hong Kong Tax Treaty
On November 11, 2012, the Government of Canada signed a tax treaty with the Government of the Hong Kong Special Administrative Region of the People’s Republic of China (referred to herein as “Hong Kong”) for the avoidance of double taxation […]
Cross-Border Tax: Canadian Multinationals Allowed to Double-Dip
Historically, Canadian multinationals have generally been entitled to deduct interest incurred in respect of borrowed funds used to invest, directly or indirectly, in foreign affiliates. The deductibility of interest related to the financing of foreign affiliates combined with the favourable […]
Surplus Stripping: Is the Pipeline Leaking Again?
On April 25, 2013, the Federal Court of Appeal (“FCA”) released its decision in the case of MacDonald v. R (2013 FCA 110) (“MacDonald”). Unfortunately for the taxpayer, the FCA in a unanimous decision overturned the decision of Justice Hershfield of […]
Surplus Stripping Limits Clarified
Although the taxpayers were largely unsuccessful in the case of Descarries v. R., 2014 TCC 75, the decision of Tax Court Judge Hogan J. provides a useful analysis of the limits to be applied to “surplus stripping” and contains much that is […]
( Available in French only )
Planification de vente d’achalandage – Incidences fiscales du budget fédéral de 2016
Les immobilisations admissibles comprennent les listes de clients, les droits de franchise, les permis, les licences, les quotas et d’autres biens incorporels. Elles comprennent également l’achalandage, qui correspond de façon générale à l’excédent de la valeur d’une société sur la […]
The “Delaware – Canco Straddle” for Canadian Tech Start-Ups
Canadian start-ups, including those in the information technology sector (i.e. mobile apps, computer software and other information technologies (“IT”)) may benefit from certain tax and corporate advantages of operating both a Canadian corporation (“CanCo”) and a U.S.-based corporation (often a […]
