Alexandra David

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Funding M&A Deals with Bitcoin

By Alexandra David on April 1, 2021 Posted in M&A, Technology and innovation

As Bitcoin gains increasing traction since its inception 11 years ago, we begin to question whether it will slowly replace traditional dollar funding in M&A deals. Whether Bitcoin will be used to fund large M&A deals will likely depend on its ability to stabilize in value. One of the most common concerns of using Bitcoin … Continue reading

Digital Taxation – Novel Considerations in M&A Transactions

By Alexandra David on November 24, 2020 Posted in M&A, Tax

Digital taxes have become a subject of significant debate in recent years. Following allegations that tech giants have paid very little tax anywhere in the world, some countries have moved to impose new taxes on profits derived from digital services provided by multinational enterprises on a jurisdiction-specific basis. For instance, France recently adopted a digital … Continue reading

Shareholder Loans: The Interplay of 80.4, 15(2) and 20(1)(j) of the Income Tax Act

By Carl Deeprose (Toronto) and Alexandra David on November 5, 2020 Posted in Tax

Subject to certain exceptions, where a shareholder (other than a corporation resident in Canada) of a corporation is indebted to the corporation (a “Shareholder Loan”), the shareholder is deemed by subsection 80.4(2) to receive an interest benefit to the extent that the notional interest on the Shareholder Loan, calculated at the prescribed rate, exceeds the … Continue reading