Tag archives: tax treaties

Private equity and Canadian partnerships: tax considerations

By Troy Ungerman (Toronto) on June 7, 2018 Posted in Finance, Real estate

Canada continues to be an attractive market for private equity (“PE“) investors with recent transactions highlighting significant investments into Canadian real estate and energy infrastructure assets. Partnerships (particularly, limited partnerships) continue to be a popular PE vehicle, providing a means of pooling and aggregating investment funds and allowing for income or losses to be “flowed-through” … Continue reading

OECD report proposes new treaty shopping rules

By Troy Ungerman (Toronto) on November 10, 2015 Posted in Corporate finance, Tax

In February we wrote about a discussion draft of Action 6 of the Action Plan on Base Erosion (BEPS Action Plan) developed by the Organisation for Economic Co-Operation and Development (OECD) at the request of the G20. In October, the OECD published its final report on Action 6 of the BEPS Action Plan. Action 6 … Continue reading