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Articles by Michael Cardinal
SupplierGateway and Certificial Announce Strategic Partnership to Deliver Real-Time Supplier Insurance Management
A new integration brings live, automated supplier insurance compliance and real-time risk visibility to procurement teams—eliminating outdated COI workflows.
IRS Proposed Regulations Would Narrow The Exemption For Passive Income Of Foreign Governments Under Section 892
DW Davies Ward Phillips & Vineberg More Davies is a law firm focused on high-stakes matters. Committed to achieving superior outcomes for our clients, we are consistently at the heart of their most complex deals and cases. With offices in Toronto, Montréal and New York, our capabilities extend seamlessly to every continent. Visit us at www.dwpv.com.
IRS Proposed Regulations Would Narrow the Exemption For Passive Income of Foreign Governments Under Section 892 | JD Supra
The Internal Revenue Service (IRS) and the U.S. Treasury Department last Friday released final and proposed regulations addressing various rules under section 892. The rules are a mixed bag – some are favourable and provide clarity, while others may be unfavourable – and ambiguity may lead taxpayers to take more conservative positions.
IRS Withdraws Controversial "Funding Rule" For Stock Buyback Excise Tax
Davies Ward Phillips & Vineberg are most popular: in Canada with readers working within the Construction & Engineering industries The Internal Revenue Service (IRS) and U.S. Treasury Department have issued final regulations (T.D. 10037) (Final Regulations) under Section 4501 of the Code (the Excise Tax) that withdraw the previously proposed "funding rule." The broad scope of that rule had been controversial.
IRS Withdraws Controversial "Funding Rule" for Stock Buyback Excise Tax | JD Supra
The Internal Revenue Service (IRS) and U.S. Treasury Department have issued final regulations (T.D. 10037) (Final Regulations) under Section 4501 of the Code (the Excise Tax) that withdraw the previously proposed "funding rule." The broad scope of that rule had been controversial. Under the funding rule, foreign parented groups would have been subjected to the Excise Tax on transactions in which a U.S. affiliate was deemed to have indirectly provided funding for a stock repurchase.
IRS Proposed Regulations Restore Key FIRPTA Relief For REIT Structures
Davies Ward Phillips & Vineberg are most popular: with Finance and Tax Executives in Canada with readers working within the Accounting & Consultancy industries The Internal Revenue Service (IRS) and U.S. Treasury Department have proposed regulations (the Proposed Regulations) that would expand FIRPTA (Foreign Investment in Real Property Tax Act) relief for domestically controlled REITs (real estate investment trust) by repealing the corporate look-through rule introduced by final U.S....
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